2005/12/19-oyster creek license renewal - aging management ... · license renewal project page 7 of...

,, .... - 11 -111- - � -I I I-, - - - - -I[ D. Ashl 6 ... y' 4--iiial four AMP program basis documents ''I I-, -11111 --- I'll - "I - ,,, I I I I � - � 1I D. Ashley - Final four AMP program basis documents Page 1

From: <[email protected]>To: <djal @nrc.gov>, <gvc~nrc.gov>Date: 12/19/2005 5:38:26 PMSubject: Final four AMP program basis documents

Donnie/Greg,

Here are the final four AMP PBDs that we had indicated we would provide in response to your AMP Auditquestion AMP-147. This brings to 35 the number of upgraded program basis documents that we haveprovided, enabling the AMP team Auditors to continue their review activities, leading up to the Audit ofJanuary 23, 2006.

Attached please find the following four PBDs in Word format:PBD B.1.14 CCCW, Rev. 0PBD B.1.32 Water Control Structures, Rev. 0PBD B.1.26 Buried Piping, Rev. 0PBD B.1.07 BWR SCC, Rev. 0.

Note that these Word files have been "write" protected to prevent inadvertent revisions to the files. Thisshould not preclude viewing, copying, pasting, etc. Let us know if there are any problems.

As you know, these are being provided in response to AMP Audit question AMP-147. An updatedresponse to Audit question AMP-147, is also attached, which reflects that we have provided all the AMPbasis documents in support of the upcoming AMP Audit to be conducted the week of January 23, 2006.

Please let me know if there are any questions/problems. Thanks.

- John.

<<PBD B.1.14 CCCW Rev.O.doc>> «<PBD B.1.32 Water Control Structures Rev. O.doc» <<PBDB.1.26 Buried piping Rev O.doc> <<PBD B.1.7 BWR SCC Rev O.doc>>

«<12-19-05 Update to AMP-1 47 Response.pdf>>

This e-mail and any of its attachments may contain Exelon Corporationproprietary information, which is privileged, confidential, or subjectto copyright belonging to the Exelon Corporation family of Companies.This e-mail Is intended solely for the use of the individual or entityto which it is addressed. If you are not the intended recipient of thise-mail, you are hereby notified that any dissemination, distribution,copying, or action taken in relation to the contents of and attachmentsto this e-mail Is strictly prohibited and may be unlawful. If you havereceived this e-mail in error, please notify the sender immediately andpermanently delete the original and any copy of this e-mail and anyprintout. Thank You.

CC:- <[email protected]>, <donald.warfel @exeloncorp.com>

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Subject: Final four AMP program basis documentsCreation Date: 12/19/2005 5:37:12 PMFrom: <[email protected]>

Created By: [email protected]

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OWGWPO01.HQGWDO01DJA1 (D. Ashley)

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exeloncorp.comdonald.warfel CCfred.polaski CC

Post OfficeOWGWPOO1.HQGWDO01owf4_po.OWFNDO

Files SizeMESSAGE 2201TEXT.htm 3478PBD B.1.14 CCCW Rev.0.doc 242176PBD B.1.32 Water Control Structures Rev. 0.docPBD B.1.26 Buried piping Rev 0.docPBD B.1.7 BWR SCC Rev 0.doc12-19-05 Update to AMP-147 Response.pdfMime.822 1992522

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r'D. A-s-hleyv- PB' XB.1 .14 CCC-W Rev.O.doc Page111 1IlD. .-. Ashley -o PBD -B.4 C--W RO- -a== 1 w

Oyster Creek PBD-AMP-B.1.14, Revision 0License Renewal Project Page 1 of 41Closed Cycle Cooling Water Systems

PROGRAM BASIS DOCUMENT

PBD-AMP-B.1 .14

Revision 0

CLOSED CYCLE COOLING WATER SYSTEMS

GALL PROGRAM XL.M21 - CLOSED CYCLE COOLING WATER SYSTEMS

Prepared By:

Reviewed By:

Program Owner Review:

Technical Lead Approval:

Revision History:Revision Prepared by:. Reviewed by: Program Approved by:.

____ ___ _ _ _ _ _ _ _ _ _ _ _ ___ ___ ___O w n er:

0 S. Rafferty- George Beck Bob Barbieri/ Fred PolaskiCzincila Mike Ford

Date

D. Ashley - PBD B.1.14 CCCW Rev.O.doc Paqe 2

Oyster CreekLicense Renewal ProjectClosed Cycle Cooling Water Systems

PBD-AMP-B.1.14, Revision 0Page 2 of 41

Summary of Revisions:

Rev. Number Reason for the Revision(s)Initial Issue

4-

[D.Ashley : ePt b-1. 1 4 CCCW Rev.O.doc pi�6'� II D. Ashley - PBD BA .14 CCCW Rev.O.doc Page 3 1


TABLE OF CONTENTS

1.0 PURPOSE AND METHODOLOGY 41.1 Purpose 41.2 Methodology 4

2.0 PROGRAM DESCRIPTION 52.1 Program Description 52.2 Overall NUREG-1801 Consistency 82.3 Summary of Exceptions to NUREG-1 801 82.4 Summary of Enhancements to NUREG-1801 9

3.0 EVALUATIONS AND TECHNICAL BASIS 93.1 Scope of Program 93.2 Preventive Actions 1

03.3 Parameters Monitored or Inspected 1

33.4 Detection of Aging Effects 1

73.5 Monitoring and Trending 2

23.6 Acceptance Criteria 2

43.7 Corrective Actions 2

63.8 Confirmation Process 2

83.9 Administrative Controls 2

3.10 Operating Experience 29

3.11 Conclusion 32

4.0 REFERENCES 32

4.1 Generic to Aging Management Programs 32

4.2 Industry Standards 33

4.3 Oyster Creek Program References 33

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5.0 Tables 33

5.1 Aging Management Program Implementing Documents 33

5.2 Aging Management Review Results 36

6.0 Attachments 45

6.1 LRA Appendix A6.2 LRA Appendix B

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1.0 PURPOSE AND METHODOLOGY

1.1 Purpose

The purpose of this Program Basis Document is to document andevaluate those activities of the Oyster Creek Closed Cycle CoolingWater aging management program that are credited for managingaging of piping, piping components, piping elements, pumps andheat exchangers that are included in the scope of license renewalfor loss of material and reduction of heat transfer and are exposedto a closed cooling water environment at Oyster Creek as part ofOyster Creek License Renewal to meet the requirements of theLicense Renewal Rule 10 CFR 54, "Requirements for Renewal ofOperating Licenses for Nuclear Power Plants."

This includes the following:

* The identification of the scope of the program;

* The evaluation of program elements against NUREG-1801;

* The review of Operating Experience to demonstrateprogram effectiveness;

* The identification of required program enhancements;

* The identification of Oyster Creek documents requiredimplementing the program.

1.2 Methodology

The nuclear power plant License Renewal Rule 10 CFR 54,"Requirements for Renewal of Operating Licenses for NuclearPower Plants," describes the License Renewal process andprovides requirements for the contents of License RenewalApplications. 10 CFR 54.21 (a)(3) states:

"For each structure and component identified in paragraph (a)(1) ofthis section, demonstrate that the effects of aging will beadequately managed so that the intended function(s) will bemaintained consistent with the Current Licensing Basis (CLB) forthe period of extended operation."

The NRC and the industry identified 10 program elements that areuseful in describing an aging management program and thendemonstrating its effectiveness. These program elements aredescribed in Appendix A.1, Section A.1.2.3 of the Standard Review

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Plan. NUREG-1 801 uses these program elements in Section Xl todescribe acceptable aging management programs.

This Program Basis Document also provides a comparison of thecredited Oyster Creek program with the elements of thecorresponding NUREG-1 801 Chapter Xl program XI.M21. ProjectLevel Instruction PLI-8 "Program Basis Documents" prescribes themethodology for evaluating Aging Management Programs. Anevaluation of Oyster Creek's aging management program criteriaoractivities to those of the NUREG-1 801 program elements isperformed and a conclusion is reached concerning consistency foreach individual program element. A demonstration of overallprogram effectiveness is made after all program elements areevaluated. Required program enhancements are documented. Anoverall determination is made as to consistency with the programdescription in NUREG-1801.

2.0 PROGRAM DESCRIPTION

2.1 Program Description

NUREG-1 801:

a) The program includes (a) preventive measures to minimizecorrosion and stress corrosion cracking (SCC) and (b) testingand inspection to monitor the effects of corrosion and SCC onthe intended function of the component.

b) The program relies on maintenance of system corrosioninhibitor concentrations within the specified limits of ElectricPower Research Institute (EPRI) TR-107396 to minimizecorrosion and SCC.

c) Non-chemistry monitoring techniques such as testing andinspection in accordance with guidance in EPRI TR-107396 forclosed-cycle cooling water (CCCW) systems provide oneacceptable method to evaluate system and componentperformance. These measures will ensure that the intendedfunctions of the CCCW system and components serviced by theCCCW system are not compromised by aging.

Oyster Creek:

a) The Oyster Creek Closed Cycle Cooling Water System agingmanagement program is an existing program that providescondition monitoring, preventive measures, inspections, andperformance testing activities to manage loss of material,cracking, and buildup of deposit aging effects in components in

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the scope of license renewal exposed to closed-cycle coolingwater environments. Oyster Creek controls the risks of StressCorrosion Cracking (SCC) in the CCCW'systems by maintainingtheir Chloride and Fluoride levels each below 10 ppm asrecommended in Table A.1 of the EPRI 1007820, "ClosedCooling Water Chemistry Guideline, Revision 1". The OysterCreek actual limit is < 8ppm with and action level of > 10 ppmfor both Fluoride and Chloride. (Reference: CY-AA-120-400)Additionally the EDGCCW, RBCCW and TBCCW heatexchangers are either horizontally mounted, or not applicable(i.e. radiators) to the guidance in EPRI 1007820 Section A.1which states that "SCC is much more likely in verticalexchangers than in horizontal exchangers. This is due toevaporation and increasing temperatures in the vapor zone,below the top tube sheet. The CCW system heat exchangersunder consideration are normally horizontal and are not proneto this (SCC) failure mode." Section A.1 of EPRI 1007820further states that the impurity levels of less than 10 ppm areconservative and represent a very low, acceptable risk.

(a) Preventive activities include measures to mitigate loss ofmaterial and buildup of deposit aging effects in componentsby maintaining water purity and corrosion inhibitors tominimize corrosion.

(b) Performance testing and system and component inspectionsmonitor the effects of corrosion on the intended function ofthe component.

b) NUREG 1801 refers to EPRI TR-107396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implementsthe guidance provided in EPRI 1007820, 'Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision toTR-1 07396 to minimize corrosion. Oyster Creek controls therisks of Stress Corrosion Cracking (SCC) in the CCCW systemsby maintaining their Chloride and Fluoride levels each below 10ppm as recommended in Table A.1 of the EPRI 1007820. TheOyster Creek actual limit is < 8ppm with and action level of >10 ppm for both Fluoride and Chloride. (Reference: CY-AA-1 20-400) Additionally the EDGCCW, RBCCW and TBCCW heatexchangers are either horizontally mounted, or not applicable(i.e. radiators) to the guidance in EPRI 1007820 Section A.1which states that "SCC is much more likely in verticalexchangers than in horizontal exchangers. This is due toevaporation and increasing temperatures in the vapor zone,below the top tube sheet. The CCW system heat exchangers

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under consideration are normally horizontal and are not proneto this (SCC) failure mode." Section A.1 of EPRI 1007820further states that the impurity levels of less than 10 ppm areconservative and represent a very low, acceptable risk.

c) Non-chemistry monitoring techniques, such as surveillancetests, include performance monitoring of the Turbine BuildingClosed Cooling, Reactor Building Closed Cooling andEmergency Diesel Generator Closed Cooling Water. Plantoperating conditions would provide indications of degradation innormally operating systems. These testing and inspectionactivities verify system operability and ensure that aging effectsare managed such that system and component functions aremaintained. Testing and inspection in accordance with guidancein EPRI 1007820 for closed-cycle cooling water (CCCW)systems provide one acceptable method to evaluate systemand component performance. These measures will ensure thatthe intended functions of the CCCW system and componentsserviced by the CCCW system are not compromised by aging.

Control of CCCW Chemistry in accordance with EPRIguidelines (1007820) does not preclude buildup of deposits andloss of material due to general, crevice, or pitting corrosion atlocations of stagnant flow conditions. A one-time inspection inaccordance with B.1.24, One-Time Inspection Program, ofcomponents in the scope of license renewal with leakageboundary and leakage boundary/structural support intendedfunctions exposed to closed cycle cooling water will beconducted to confirm the absence of aging effects in stagnantflow areas.

For heat exchangers, an aging management program that usesmultiple attributes is considered necessary to effectivelyaddress all aging effects. The Open Cycle Cooling Water AMPactivities provide input into a program that includes primary andsecondary operating fluid chemistry controls, performancemonitoring, and inspections of all heat exchangers in the scopeof License Renewal at Oyster Creek to manage loss of materialand reduction of heat transfer as a result of buildup of deposit.(Reference: PBD-AMP-B.11.13)

2.2 Overall NUREG-1801 Consistency

The Oyster Creek Closed Cycle Cooling Water System agingmanagement program is an existing program that is consistent withNUREG-1 801 aging management program XI.M21, Closed Cycle

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Cooling Water Systems with exceptions as described in 2.3 below.

2.3 Summary of Exceptions to NUREG-1 801

NUREG 1801 refers to EPRI TR-107396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implements theguidance provided in EPRI 1007820 "Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision to TR-107396. EPRI periodically updates industry water chemistryguidelines, as new information becomes available. Oyster Creekhas reviewed EPRI 1007820 and has determined that the mostsignificant difference is that the new revision provides moreprescriptive guidance and has a more conservative monitoringapproach. EPRI 1007820 meets the same requirements of EPRITR-1 07396 for maintaining conditions to minimize corrosion andmicrobiological growth in closed cooling water systems foreffectively mitigating aging effects.

2.4 Summary of Enhancements to NUREG-1 801

None. The existing Oyster Creek Oyster Creek Closed CycleCooling Water aging management program is found to beadequate to support the extended period of operation with noenhancements.

3.0 EVALUATIONS AND TECHNICAL BASIS

Note

This section is organized by quoting the relevant NUREG-1 801 ChapterXl program element (September 2005 version) followed by the relatedOyster Creek program attributes and a conclusion of the comparison.Where applicable, the NUREG-1 801 program element was separatedinto logical sub-elements and addressed accordingly.

Implementing procedure references are included in ()for informationpurposes. This information from the source procedure has been eitherdirectly extracted from the procedure or summarized for inclusion intothis PBD.

3.0 Scope of Program

NUREG-1 801:

A CCCW system is defined as part of the service water system thatis not subject to significant sources of contamination, in whichwater chemistry is controlled and in which heat is not directly

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rejected to a heat sink. The program described in this sectionapplies only to such a system. If one or more of these conditionsare not satisfied, the system is to be considered an open-cyclecooling water system. The staff notes that if the adequacy ofcooling water chemistry control cannot be confirmed, the system istreated as an open-cycle system as indicated in Action Ill ofGeneric Letter (GL) 89-13.

Oyster Creek:

The systems and portions of systems crediting Closed-CycleCooling Water System activities for aging management are: (1) notsubject to significant sources of contamination, (2) systems wherewater chemistry is controlled, and (3) systems where heat is notdirectly rejected to a heat sink.

The components within the scope of License Renewal that aresubject to Closed-Cycle Cooling Water System activities areincluded in Turbine Building Closed Cooling, Reactor BuildingClosed cooling and Emergency Diesel Generator Closed CoolingWater systems. Chemistry control activities and surveillance testingand inspection activities are controlled by corporate and stationprocedures. (Reference: CY-OC-120-110, CY-AA-120-400,309.1.1,341, 636.1.010, 636.4.003, 636.4.013, 642.4.001,PMIVT0015, PM00120M, PM00184M, PM00189M and PM00209M)

The Oyster Creek Closed Cycle Cooling Water aging managementprogram manages the aging effect of piping, piping components,piping elements, pumps and heat exchangers that are included inthe scope of license renewal for loss of material and reduction ofheat transfer and are exposed to a closed cooling waterenvironment at Oyster Creek for the systems, components, andenvironments listed in Table 5.2. The implementing documents forthis aging management program are listed in Table 5.1 and aredescribed throughout the individual program element discussions.The commitment numbers under which these implementingdocuments are being revised are contained within the listings inTable 5.1.

Exceptions to NUREG-1801. Element 1:

None.

Enhancements to NUREG-1 801. Element 1:

None.

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Comparison and Evaluation Conclusion:

This element is consistent with NUREG-1 801, Element 1, Scope ofProgram.

3.1 Preventive Actions

NUREG-1 801:

a) The program relies on the use of appropriate materials, lining,or coating to protect the underlying metal surfaces and maintainsystem corrosion inhibitor concentrations within the specifiedlimits of EPRI TR-107396 to minimize corrosion and SCC.

b) The program includes monitoring and control of cooling waterchemistry to minimize exposure to aggressive environments

c) Application of corrosion inhibitor in the CCCW system tomitigate general, crevice, and pitting corrosion as well as SCC.

Oyster Creek:

a) Materials are determined by as-built configuration andspecifications for Oyster Creek. Linings or coatings are notcredited. Closed-Cycle Cooling Water System activitiesconducted under corporate and station procedures includeperiodic monitoring and controlling of water chemistry and/orcorrosion inhibitor concentrations within specified limits of EPRI1007820 for nitrite and molybdate inhibitor based CCWsystems. Chemistry control activities are controlled by corporateand station procedures. (Reference: CY-AA-120-400 and CY-OC-120-110) Oyster Creek controls the risks of StressCorrosion Cracking (SCC) in the CCCW systems by maintainingtheir Chloride and Fluoride levels each below 10 ppm asrecommended in Table A.1 of the EPRI 1007820, "ClosedCooling Water Chemistry Guideline, Revision 1". The OysterCreek actual limit is < 8ppm with and action level of > 10 ppmfor both Fluoride and Chloride. (Reference: CY-AA-120-400)Additionally the EDGCCW, RBCCW and TBCCW heatexchangers are either horizontally mounted, or not applicable(i.e. radiators) to the guidance in EPRI 1007820 Section A.1which states that USCC is much more likely in verticalexchangers than in horizontal exchangers. This is due toevaporation and increasing temperatures in the vapor zone,below the top tube sheet. The CCW system heat exchangersunder consideration are normally horizontal and are not proneto this (SCC) failure mode." Section A.1 of EPRI 1007820

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further states that the impurity levels of less than 10 ppm areconservative and represent a very low, acceptable risk.

b) The program includes monitoring and control of cooling waterchemistry to minimize exposure to aggressive environments.Application of corrosion inhibitor in the CCCW system tomitigate general, crevice, and pitting corrosion in accordancewith EPRI 1007820 as follows (Reference: CY-AA-120-400):

Systems with Nitrite Inhibitor (EDGCCW) have the followingControl Program:

Nitrite: 600-1500 ppm- Action Level 1: <500 ppm, Action Level2: <300 or >4000 ppm - Monthly or as Operated

pH: 9.0 to 10.5 - Action Level 1: <8.5 or >11.0, Action Level 2:<8.0 or >11.5 - Monthly or as Operated

Azole: 10 to 100 ppm azole - Action Level 1: <5 ppm, ActionLevel 2: <3 ppm - Monthly or as Operated

Chloride & Fluoride: <8 ppm Cl, <8 ppm F - Action Level 2: >10ppm - Monthly or as Operated

Systems with Nitrite Inhibitor (EDGCCW) DiagnosticParameters:

Conductivity - Consistent with Nitrite Level and Evaluate Trend -Monthly or as Operated

Nitrate - Evaluate Trend - Quarterly or as Operated

Ammonia - Evaluate Trend - Quarterly

Chloride & Sulfate - Evaluate Trend - Monthly or as Operated

Total Iron, Total Copper - Evaluate Trend - Monthly or asOperated

Microbiological - <104 CFU/ml or <1 ng/ml Microbial -Adenosine TriphosphatelATP) - Monthly or as Operated

Isotopic Activity - Evaluate Trend - Quarterly or as Operated

Systems with Molybdate Inhibitor (RBCCW & TBCCW) havethe following Control Program:

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Molybdate: 250-1000 ppm as MoO4- Action Level 1: <200 ppm,Action Level 2: <160 - Weekly

pH: 9.2 to 10.8 - Action Level 1: <9.0 or >11.0, Action Level 2:<8.5 or >11.5 - Weekly

Azole: 10 to 100 ppm as TTA - Action Level 1: <5 ppm, ActionLevel 2: <3 ppm - Monthly

Chloride & Fluoride: <8 ppm Cl, 58 ppm F - Action Level 2: >10ppm - Monthly

Systems with Molvbdate Inhibitor (RBCCW & TBCCW)Diagnostic Parameters:

Conductivity - Evaluate Trend - Weekly

Chloride & Sulfate - Evaluate Trend - Monthly

Iron & Copper - Evaluate Trend - Monthly

Microbiological - <1 04 CFU/ml or <1 ng/ml Microbial - ATP -Quarterly

Isotopic Activity - Evaluate Trend - Quarterly

c) Application of a Nitrite inhibitor is used in the EDGCCCW andapplication of a Molybdate Inhibitor is used in the RBCCW andTBCCW systems to mitigate general, crevice, and pittingcorrosion in accordance with EPRI 1007820. (Reference: CY-AA-120-400)

Exceptions to NUREG-1 801. Element 2:

NUREG 1801 refers to EPRI TR-1 07396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implements theguidance provided in EPRI 1007820 "Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision to TR-107396. EPRI periodically updates industry water chemistryguidelines, as new information becomes available. Oyster Creekhas reviewed EPRI 1007820 and has determined that the mostsignificant difference is that the new revision provides moreprescriptive guidance and has a more conservative monitoringapproach. EPRI 1007820 meets the same requirements of EPRI

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TR-1 07396 for maintaining conditions to minimize corrosion andmicrobiological growth in closed cooling water systems foreffectively mitigating many aging effects.

Enhancements to NUREG-1 801, Element 2:

None.


This element is consistent with NUREG-1 801, Element 2,Preventive Actions with exceptions as described above.

3.2 Parameters Monitored or Inspected

NUREG-1 801:

a) The aging management program monitors the effects ofcorrosion and SCC by testing and inspection in accordance withguidance in EPRI TR-107396 to evaluate system andcomponent condition:

b) For pumps, the parameters monitored include flow, dischargepressures, and suction pressures.

c) For heat exchangers, the parameters monitored include flow,inlet and outlet temperatures, and differential pressure.

Oyster Creek:

a) The aging management program monitors the effects ofcorrosion and SCC by system surveillance testing andcomponent inspections in accordance with guidance in EPRI1007820 to evaluate system and component condition.(Reference: 309.1.1, 341, 642.4.001, 636.4.003, 636.4.013,PM00120M, PM00184M, PM00189M and PM00209M)

Oyster Creek controls the risks of Stress Corrosion Cracking(SCC) in the CCCW systems by maintaining their Chloride andFluoride levels each below 10 ppm as recommended in TableA.1 of the EPRI 1007820, "Closed Cooling Water ChemistryGuideline, Revision 1". The Oyster Creek actual limit is < 8ppmwith and action level of > 10 ppm for both Fluoride and Chloride.(Reference: CY-AA-1 20-400) Additionally the EDGCCW,RBCCW and TBCCW heat exchangers are either horizontallymounted, or not applicable (i.e. radiators) to the guidance in

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EPRI 1007820 Section A.1, which states "SCC is much morelikely in vertical exchangers than in horizontal exchangers. Thisis due to evaporation and increasing temperatures in the vaporzone, below the top tube sheet. The CCW system heatexchangers under consideration are normally horizontal and arenot prone to this (SCC) failure mode." Section A.1 of EPRI1007820 further states that the impurity levels of less than 10ppm are conservative and represent a very low, acceptable risk.

If parameter limits are exceeded, the chemistry controlprocedures require that corrective action be taken to restoreparameters within the acceptable range. CCW Action Level 1conditions are those that can be addressed using the 12-weekwork schedule concept, with no discernable increases incorrosion rates or impact on system efficiency. CCW ActionLevel 1 denotes a condition where system chemistry ControlParameters are outside the normal operating levels (Goalrange). The recommended action is to increase monitoringfrequency, as appropriate, and return the parameter to withinthe prescribed Goal range within 90 days. If the parameter hasnot returned to the normal operating range within 90 days, CCWAction Level 2 is entered. CCW Action Level 2 communicates amore serious condition, requiring action outside the normal 12-week work schedule. Values exceeding the CCW Action Level2 threshold could initiate short-term system materialsdegradation. The recommended action is to return theparameter to within the prescribed Goal range within thirty (30)days. If after 30 days in CCW Action Level 2 the parameter hasnot returned to the normal range, and system operation is tocontinue, then a risk assessment (engineering evaluation) shallbe performed indicating that the out of control parameter will notimpact the long term reliability of the system. . (Reference: CY-AA-120-400)

b) For pumps, the parameters monitored include flow, dischargepressures, and suction pressures. (Reference: 309.1.1, 341,642.4.001, 636.4.003, 636.4.013)

EDG inspection activities monitor for loss of material andbuildup of deposit aging effects every 2 years. (Reference:636.1.010) EDG operability tests are performed monthly andverifying proper coolant temperature during system operationunder load. (Reference: 341) The system is inspected for pumpleaks and piping leaks after every run. Because the system isoperated monthly, any indications of the EDGCCW systemdegradation would be evident by increased engine

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temperatures. Additionally, the EDG water pumps are replacedevery 2 years per the implementing activities listed at the end ofthis document. (Reference: PM86104A and PM86104 B)

The RBCCW system is tested quarterly as part of the ISTprogram therefore all required operational parameters; pumpflow and discharge/suction pressures and heat exchangers flow,temperatures and differential pressure are tested andmonitored. (Reference: 642.4.001) The TBCCW systemoperating parameters such as pump discharge/suctionpressures and heat exchanger temperatures and differentialpressure are monitored. (Reference: 309.1.1) System flows,temperatures, and discharge/suction pressures are monitoredas part of normal plant operational surveillances. Performancetesting and inspections monitor both process sides of applicableheat exchangers. The delta P across the RBCCW & TBCCWheat exchangers is monitored. Increased delta P is an indicationof fouling/heat transfer degradation. Cleanings are schedulewhen delta P limits are reached. Additionally the RBCCW &TBCCW heat exchangers are cleaned and inspected annually.(Reference: PM00120M, PM00184M, PM00189M andPM00209M)

System walkdowns are performed in accordance with thesystem manager walkdown procedure which requires thesystem manager to look at System parameters normal(temperature/pressure/DP/flow/water levels) and Materielcondition of components, supports, etc. (Reference: ER-AA-2030)

For components in the scope of license renewal with leakageboundary (spatial) and structural integrity (attached), intendedfunctions (a)(2) that may be exposed to stagnant flow areas, aone-time inspection in accordance B.1.24, One-Time InspectionProgram, will be conducted to confirm the absence of agingeffects. (Reference: PBD-AMP-B.11.24)

c) For heat exchangers, the parameters monitored include flow,inlet and outlet temperatures, and differential pressure as partof system operating procedures. (Reference: 341, 642.4.001and 309.1.1)

Excentions to NUREG-1 801. Element 3:

NUREG 1801 refers to EPRI TR-1 07396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implements the

F D.0A-s'h--e-v- P-B D-0B.1-.14 'CC CW Rev. O. doc^ Page 17 ifD. Ashly. -: PBD=.i:i~iJ~zW , B 4 C W Rc _a_ . 17


guidance provided in EPRI 1007820 "Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision to TR-107396. EPRI periodically updates industry water chemistryguidelines, as new information becomes available. Oyster Creekhas reviewed EPRI 1007820 and has determined that the mostsignificant difference is that the new revision provides moreprescriptive guidance and has a more conservative monitoringapproach. EPRI 1007820 meets the same requirements of EPRITR-1 07396 for maintaining conditions to minimize corrosion andmicrobiological growth in closed cooling water systems foreffectively mitigating many aging effects.


None.


This element is consistent with NUREG-1 801, Element 3,Parameters Monitored or Inspected with exceptions as describedabove.

3.3 Detection of Aging Effects

NUREG-1 801:

a) Control of water chemistry does not preclude corrosion or SCCat locations of stagnant flow conditions or crevices. Degradationof a component due to corrosion or SCC would result indegradation of system or component performance. The extentand schedule of inspections and testing should assure detectionof corrosion or SCC before the loss of the intended function ofthe component.

b) Performance and functional testing ensures acceptablefunctioning of the CCCW system or components serviced by theCCCWsystem.

c) For systems and components in continuous operation,performance adequacy should be verified by monitoringcomponent performance through data trends for evaluation ofheat transfer capability, system branch flow changes andchemistry data trends.

d) Components not normally in operation are periodically tested toensure operability.

Oyster Creek:

BD y B.194 CCCW Re.O.docPe


a) Control of CCCW Chemistry in accordance with EPRIguidelines (EPRI 1007820, "Closed Cooling Water ChemistryGuideline, Revision 1") does not preclude buildup of depositsand loss of material due to general, crevice, or pitting corrosionat locations of stagnant flow conditions. A one-time inspectionin accordance with B.1.24 of components exposed to closedcycle cooling water will be conducted to confirm the absence ofaging effects in stagnant flow areas. Oyster Creek controls therisks of Stress Corrosion Cracking (SCC) in the CCCW systemsby maintaining their Chloride and Fluoride levels each below 10ppm as recommended in Table A.1 of the EPRI 1007820. TheOyster Creek actual limit is < 8ppm with and action level of >10 ppm for both Fluoride and Chloride. (Reference: CY-AA-1 20-400) Additionally the EDGCCW, RBCCW and TBCCW heatexchangers are horizontal and per EPRI 1007820 Section A.1:"SCC is much more likely in vertical exchangers than inhorizontal exchangers." And that uThe CCW system heatexchangers under consideration are normally horizontal and arenot prone to this (SCC) failure mode." Section A.1 of EPRI1007820 further states that the impurity levels of less than 10ppm are conservative and represent a very low, acceptable risk.

Periodic inspections of heat exchangers serviced by closedcycle cooling water systems are performed as part of the OpenCycle Cooling Water aging management program B.1.13 andprovide an opportunity to detect degradation in areas ofstagnant flow in heat exchangers in the scope of licenserenewal. (Reference: PBD-AMP-B.1.13)

b) Performance and functional testing ensures acceptablefunctioning of the CCCW system or components serviced by theCCCW system.

Performance monitoring and functional testing verify operabilityof the EDG as required by Plant Technical Specifications 4.7.RBCCW and EDG testing is conducted under operatingsurveillance procedures. (Reference: 642.4.001 and 341)TBCCW testing is performed under station operatingprocedures. (Reference: 309.1.1) These tests are conductedwith sufficient frequency to detect component degradation priorto loss of intended function.

c) For normally operating systems, performance is monitored aspart of normal plant operational procedures and surveillances.(Reference: 309.1.1 and 642.4.001) The RBCCW system istested quarterly as part of the IST program; therefore allrequired operational parameters (pump flow and

I D. As-hley'- P'B" bB'.1.'1-4t C-CW -R'e-_v6.Odoc 0Paae 1^9-FI_1_ D_11_. Ashley - - - -PBD-.1 CC R Paae191


discharge/suction pressures and heat exchangers flow,temperatures and differential pressure) are tested andmonitored. (Reference: 642.4.001) The TBCCW systemoperating parameters such as pump discharge/suctionpressures and heat exchanger temperatures and differentialpressure are monitored by operations. (Reference: 309.1.1)System flows, temperatures, and discharge/suction pressuresare monitored as part of normal plant operational surveillances.The delta P across the RBCCW & TBCCW heat exchangers ismonitored. Increased delta P is an indication of fouling/heattransfer degradation. Cleanings are schedule when delta Plimits are reached. (Reference: 642.4.001 and 309.1.1)

The program includes monitoring and control of cooling waterchemistry to minimize exposure to aggressive environments.Application of corrosion inhibitor in the CCCW system tomitigate general, crevice, and pitting corrosion in accordancewith EPRI 1007820 as follows:

Systems with Nitrite Inhibitor (EDGCCW) have the followingControl Program:

Nitrite: 600-1500 ppm- Action Level 1: <500 ppm , Action Level2: <300 or >4000 ppm - Monthly or as Operated

pH: 9.0 to 10.5 - Action Level 1: <8.5 or >11.0, Action Level 2:<8.0 or >11.5 - Monthly or as Operated

Azole: 10 to 100 ppm azole - Action Level 1: <5 ppm, ActionLevel 2: <3 ppm - Monthly or as Operated

Chloride & Fluoride: •8 ppm Cl, •8 ppm F - Action Level 2: >10ppm - Monthly or as Operated

Systems with Nitrite Inhibitor (EDGCCW) DliaqnosticParameters:

Conductivity - Consistent with Nitrite Level and Evaluate Trend -Monthly or as Operated

Nitrate - Evaluate Trend - Quarterly or as Operated

Ammonia - Evaluate Trend - Quarterly

Chloride & Sulfate - Evaluate Trend - Monthly or as Operated

Total Iron, Total Copper - Evaluate Trend - Monthly or as

I D. Ashiev - PBD B.1.14 CCCW Rev.O.doc 00ageg2I D Ahly -PB B1 .4 CC ------ o PaaeI 20 I--


Operated

Microbiological - <104 CFU/ml or <1 ng/ml Microbial -Adenosine TriphosphateATP) - Monthly or as Operated

Isotopic Activity - Evaluate Trend - Quarterly or as Operated

Systems with Molybdate Inhibitor (RBCCW & TBCCW) havethe following Control Program:

Molybdate: 250-1000 ppm as MoO4- Action Level 1: <200 ppm,Action Level 2: <160 - Weekly

pH: 9.2 to 10.8 - Action Level 1: <9.0 or >11.0, Action Level 2:<8.5 or >11.5 - Weekly I

Azole: 10 to 100 ppm as TTA - Action Level 1: <5 ppm, ActionLevel 2: <3 ppm - Monthly

Chloride & Fluoride: •8 ppm Cl, •8 ppm F - Action Level 2: >10ppm - Monthly

Systems with Molybdate Inhibitor (RBCCW & TBCCW)Diagnostic Parameters:

Conductivity - Evaluate Trend - Weekly

Chloride & Sulfate - Evaluate Trend - Monthly

Iron & Copper - Evaluate Trend - Monthly

Microbiological - <104 CFU/ml or <1 ng/ml Microbial - ATP -Quarterly

Isotopic Activity - Evaluate Trend - Quarterly

d) Components not in operation are periodically tested to ensureoperability. EDG inspection activities monitor for loss of materialand buildup of deposit aging effects every 2 years. (Reference:636.1.010) EDG operability tests are performed monthly andverify proper coolant temperature during system operationunder load. (Reference: 636.4.003 and 636.4.013) The systemis inspected for pump leaks and piping leaks after every run.Because the system is operated monthly, any indications of theEDGCCW system degradation would be evident by increasedengine temperatures. Additionally, the EDG water pumps arereplaced every 2 years per the implementing activities listed at

BD B..14 CCCW Rev..doc P


the end of this document. (Reference: 341)

System walkdowns are performed in accordance with the systemmanager walkdown procedure which requires the system managerto look at System parameters normal(temperature/pressure/DP/flow/water levels) and Materiel conditionof components, supports, etc. (Reference: ER-AA-2030)


NUREG 1801 refers to EPRI TR-1 07396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implements theguidance provided in EPRI 1007820 "Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision to TR-107396. EPRI periodically updates industry water chemistryguidelines, as new information becomes available. Oyster Creekhas reviewed EPRI 1007820 and has determined that the mostsignificant difference is that the new revision provides moreprescriptive guidance and has a more conservative monitoringapproach. EPRI 1007820 meets the same requirements of EPRITR-1 07396 for maintaining conditions to minimize corrosion andmicrobiological growth in closed cooling water systems foreffectively mitigating many aging effects.


None.


This element is consistent with NUREG-1 801, Element 4, Detectionof Aging Effects with exceptions as described above.

3.4 Monitoring and Trending

NUREG-1 801:

a) The frequency of sampling water chemistry varies and canoccur on a continuous, daily, weekly, or as needed basis, asindicated by plant operating conditions and the type of chemicaltreatment.

b) In accordance with EPRI TR- 107396, internal visual inspectionsand performance/functional tests are to be performedperiodically to demonstrate system operability and confirm theeffectiveness of the program.

c) Tests to evaluate heat removal capability of the system and

V D. Ash"1'ev'-'_P_ B_'D___B".1'"A_4 'C'C'C'W R_'ev.0.d'o''c Pagae 2-2 4--Asl -BDB1 1 CC RvO o Pa 2


degradation of system components may also be used. Thetesting intervals should be established based on plant-specificconsiderations such as system conditions, trending, and pastoperating experience, and may be adjusted based on theresults of a reliability analysis, type of service, frequency ofoperation, or age of components and systems.

Oyster Creek:

a) Closed-Cycle Cooling Water System activities includemonitoring of water chemistry parameters and corrosioninhibitor concentrations on a system specific periodic basis asoutlined in corporate and station procedures. In nitrite andmolybdate inhibitor based CCW systems, samples are taken inaccordance with EPRI 1007820. (Reference: CY-AA-120-400)See Section 3.4 for specific parameters and limits.

b) Performance and functional testing for closed cycle coolingwater systems is implemented through plant operationalsurveillances or Technical Specification surveillances.(Reference- 341, 642.4.001 and 309.1.1) Visual inspectionsare performed to confirm the effectiveness of the program.Results of the inspections have not found any significantdegradation in the systems nor have they identified any loss ofsystem intended function. (Reference: 636.1.010, PMVT001 5,PM00120M, PM00184M, PM00189M and PM00209M) Periodictesting and examination frequencies verify componentoperability and provide indications to allow repair orreplacement if degradation is noted. System flows,temperatures, and discharge/suction pressures for normallyoperating systems are monitored as part of normal plantoperational surveillances to demonstrate system operability.

c) This frequency and scope meet the guidelines of EPRI 1007820for closed cycle cooling water systems. This has proven to beeffective in maintaining closed cycle cooling water system andcomponent intended functions by the operating experienceOyster Creek.

EDG inspection activities monitor for loss of material andbuildup of deposit aging effects every 2 years. (Reference:636.1.010) EDG operability tests are performed monthly andverify proper coolant temperature during system operationunder load in accordance with Technical SpecificationsSections 3.7.C and 4.7.A. (Reference: 341, 636.4.003 and636.4.013) Additionally, the EDG water pumps are replacedevery 2 years. (Reference: PM86104A and PM86104B)

D. Ashley - PBD B.1 .14 CCCW Rev.O.doc Page 231


The RBCCW system is tested quarterly in accordance withTechnical Specifications Sections 4.3.C and as part of the ISTprogram therefore all required operational parameters; pumpflow and discharge/suction pressures and heat exchangers flow,temperatures and differential pressure are tested andmonitored. (Reference: 642.4.001) The TBCCW systemoperating parameters such as pump discharge/suctionpressures and heat exchanger temperatures and differentialpressure are monitored by operations whenever the system is inservice. (Reference: 309.1.1) System flows, temperatures, anddischarge/suction pressures are monitored as part of normalplant operational surveillances. The delta P across the RBCCW& TBCCW heat exchangers is monitored. Increased delta P isan indication of fouling/heat transfer degradation. Cleanings areschedule when delta P limits are reached. (Reference:642.4.001 and 309.1.1)


NUREG 1801 refers to EPRI TR-1 07396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implements theguidance provided in EPRI 1007820 "Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision to TR-107396. EPRI periodically updates industry water chemistryguidelines, as new information becomes available. Oyster Creekhas reviewed EPRI 1007820 and has determined that the mostsignificant difference is that the new revision provides moreprescriptive guidance and has a more conservative monitoringapproach. EPRI 1007820 meets the same requirements of EPRITR-1 07396 for maintaining conditions to minimize corrosion andmicrobiological growth in closed cooling water systems foreffectively mitigating many aging effects.


None.


This element is consistent with NUREG-1 801, Element 5,Monitoring and Trending with exceptions as described above.

3.5 Acceptance Criteria

NUREG-1801:

LgtD.1 14 CW Rev.0.doc Paqe 241P.2


a) Corrosion inhibitor concentrations are maintained within thelimits specified in the EPRI water chemistry guidelines forCCCw.

b) System and component performance test results are evaluatedin accordance with system and component design basisrequirements.

c) Acceptance criteria and tolerances are to be based on systemdesign parameters and functions.

Oyster Creek:

a) Water chemistry, chemical additives, and corrosion inhibitorconcentrations are maintained using corporate and stationprocedures. For nitrite and molybdate inhibitor based CCWsystems, limits in these procedures-are within the limitsspecified in EPRI 1007820. (Reference: CY-AA-120-400) SeeSection 3.4 for specific parameters and limits.

b) EDG operability tests are performed monthly and verify propercoolant temperature during system operation under load inaccordance with Technical Specifications Sections 3.7.C and4.7.A. (Reference: 341, 636.4.003 and 636.4.013) TheRBCCW system is tested quarterly in accordance withTechnical Specifications Sections 4.3.C and as part of the ISTprogram; therefore all required operational parameters (pumpflow and discharge/suction pressures and heat exchangers flow,temperatures and differential pressure) are tested andmonitored. (Reference: 642.4.001) The TBCCW systemoperating parameters such as pump discharge/suctionpressures and heat exchanger temperatures and differentialpressure, are monitored by operations whenever the system isin service as part of normal plant operational surveillances.(Reference: 309.1.1)

c) Acceptance criteria and tolerancesare based on system designparameters and functions.

System and component performance test results are evaluatedin accordance with the guidelines of EPRI 1007820 as well asstation Technical Specifications. (Reference: 642.4.001,341,636.4.003 and 636.4.013)

CCW Action Level 1 conditions are those that can beaddressed using the 12-week work schedule concept, with nodiscernable increases in corrosion rates or impact on systemefficiency. CCW Action Level 1 denotes a condition where

... 1. - 11 .1 - I--- I I- -- - ___ -B.1A4 CCCW Rev-.O. doc 'Pak6 25 1I D.AsNey-PBDB.1.14 CCCWRev.0.doc Paae 251


system chemistry Control Parameters are outside the normaloperating levels (Goal range). The recommended action is toincrease monitoring frequency, as appropriate, and return theparameter to within the prescribed Goal range within 90 days. Ifthe parameter has not returned to the normal operating rangewithin 90 days, CCW Action Level 2 is entered. CCW ActionLevel 2 communicates a more serious condition, requiringaction outside the normal 12-week work schedule. Valuesexceeding the CCW Action Level 2 threshold could initiate short-term system materials degradation. The recommended actionis to return the parameter to within the prescribed Goal rangewithin thirty (30) days. If after 30 days in CCW Action, Level 2the parameter has not returned to the normal range, andsystem operation is to continue, then a risk assessment(engineering evaluation) will be performed to determine ifthe outof control parameter will impact the long term reliability of thesystem. (Reference: CY-AA-120-400)

For components in the scope of license renewal with leakageboundary (spatial) and structural integrity (attached) intendedfunctions that may be exposed to stagnant flow areas, a one-time inspection in accordance with B.1.24, One-Time InspectionProgram, will be conducted to confirm the absence of agingeffects. Inspections will be conducted using VT-3 techniquesand acceptance criteria. Results will be evaluated byengineering to determine existence and rate of aging, the needfor follow-up examinations, and appropriate corrective actions.(Reference: PBD-AMP-B.1.24)


NUREG 1801 refers to EPRI TR-107396 Closed Cooling WaterChemistry Guidelines 1997 Revision. Oyster Creek implements theguidance provided in EPRI 1007820 "Closed Cooling WaterChemistry Guideline, Revision 1" which is the 2004 Revision to TR-107396. EPRI periodically updates industry waterpchemistryguidelines, as new information becomes available. Oyster Creekhas reviewed EPRI 1007820 and has determined that the mostsignificant difference is that the new revision pro~ides moreprescriptive guidance and has a more conservatij monitoringapproach. EPRI 1007820 meets the same requirements of EPRITR-1 07396 for maintaining conditions to minimize corrosion andmicrobiological growth in closed cooling water systems foreffectively mitigating many aging effects.


[. 'C~ Rev.O doc ... ... - - , 11 -- __ - - - 1 ~- ~i X ~, II I -- "',I , ' ~- 4

I D. Ashley- PBD B.1 .14 CCCW Rev.0.doc Pacie 261


None.


This element is consistent with NUREG-1 801, Element 6,Acceptance Criteria with exceptions as described above.

3.6 Corrective Actions

NUREG-1 801:

a) Corrosion inhibitor concentrations outside the allowable limitsare returned to the acceptable range within the time periodspecified in the EPRI water chemistry guidelines for CCCW.

b) If the system or component fails to perform adequately,corrective actions are taken. As discussed in the appendix tothis report, the staff finds the requirements of 10 CFR Part 50,Appendix B, acceptable to address the corrective actions.

Oyster Creek:

a) CCW Action Level 1 conditions are those that can beaddressed using the 12-week work schedule concept, with nodiscemable increases in corrosion rates or impact on systemefficiency. CCW Action Level 1 denotes a condition wheresystem chemistry Control Parameters are outside the normaloperating levels (Goal range). The recommended action is toincrease monitoring frequency, as appropriate, and return theparameter to within the prescribed Goal range within 90 days. Ifthe parameter has not returned to the normal operating rangewithin 90 days, CCW Action Level 2 is entered. CCW ActionLevel 2 communicates a more serious condition, requiringaction outside the normal 12-week work schedule. Valuesexceeding the CCW Action Level 2 threshold could initiate short-term system materials degradation. The recommended actionis to return the parameter to within the prescribed Goal rangewithin thirty (30) days. If after 30 days in CCW Action Level 2the parameter has not returned to the normal range, andsystem operation is to continue, then a risk assessment(engineering evaluation) shall be performed indicating that theout of control parameter will not impact the long term reliabilityof the system. Corrosion inhibitor concentrations outside theallowable limits are returned to the acceptable range within thetime period specified in the EPRI water chemistry guidelines forCCCW. (Reference: CY-AA-120-400)

LPLD .1.4 C Rev.O.doc Page 274P. Ashley- PBD B.1 .14 CCCW Rev.O.doc Paae 27


b) Evaluations are performed for test or inspection results that donot satisfy established criteria and an Issue Report (IR) isinitiated to document the concern in accordance with the 10CFR Part 50, Appendix B Corrective Action Program.(Reference: CY-AA-120-400) The corrective action processensures that the conditions adverse to quality are promptlycorrected. If the deficiency is assessed to be significantlyadverse to quality, the cause of the condition is determined andan action plan is developed to preclude recurrence.


None.


None.


This element is consistent with NUREG-1 801, Element 7,Corrective Actions.

3.7 Confirmation Process

NUREG-1 801:

Site quality assurance (QA) procedures, review and approvalprocesses, and administrative controls are implemented inaccordance with the requirements of 10 CFR Part 50, Appendix B.As discussed in the appendix to this report, the staff finds therequirements of 10 CFR Part 50, Appendix B, acceptable toaddress the confirmation process and administrative controls.

Oyster Creek:

Site quality assurance (QA) procedures, review and approvalprocesses, and administrative controls are implemented inaccordance with the requirements of 10 CFR Part 50, Appendix B.


None.


PBD B.1.14 CCCW Rev.O.doc D.Asley- PB B..14 CCWev.0docPage 28

Oyster CreekLicense Renewal Project-Closed Cycle Cooling Water Systems


None.


This element is consistent with NUREG-1 801, Element 8,Confirmation Process.

3.8 Administrative Controls

NUREG-1 801:See Item 8, above.

Oyster Creek:

See Item 8, above.


None.

Enhancements to NUREG-1 801. Element 9

None.


This element is consistent with NUREG-1 801, Element 9,Administrative Controls.

3.9 Operating Experience

NUREG-1 801:Degradation of closed-cycle cooling water systems due to corrosionproduct buildup (NRC Lice'nsee Event Report [LER] 50-327/93-029-00). or through-wall c1racks in supply lines (NRC 50-280/91-019-00)has been observed In operating plants. Accordingly, operatingexperience demonstrates the need for this program.

Oyster Creek:

Review of industry operating experience has confirmedthaDegradation of closed-cycle cooling water systems det orsoproduct buildup (NRP Licensee Event Report [LE.R] 5-2/30900 - Sequoyah) or through-wall cracks in supl lines NC 0280/91-019-00 - Surry has been observed inopratingpans-

[ D. Akshley~-~ 13 .1.'14 CCCW Rev.O.doc lPade --29 d0. Ashey- PB B.1.1 -C - e - dcPae2


review of plant operating experience at Oyster Creek shows thatloss of material and reduction of heat transfer has occurred inseveral closed cooling water systems. In most cases, the existingClosed Cycle Cooling Water aging management program hasidentified the degradation and adverse chemistry trends. Actionshave been taken in a timely manner to return chemistry parametersto within acceptable limits and to investigate and repairdegradation, if necessary. The experience at Oyster Creek with theClosed Cycle Cooling Water program shows that the Closed CycleCooling Water program is effective in managing loss of materialand reduction of heat transfer by performing visual inspections ofcomponents, maintaining chemistry parameters within the EPRIrecommended limits, performing UT inspections on system pipingand monitoring system performance via station surveillanceprocedures.

Operating experience, both internal and external, is used in twoways at Oyster Creek to enhance plant programs, prevent repeatevents, and prevent events that have occurred at other plants fromoccurring at Oyster Creek. The first way in which operatingexperience is used is through the Oyster Creek OperatingExperience process. The Operating Experience process screens,evaluates, and acts on operating experience documents andinformation to prevent or mitigate the consequences of similarevents. The second way is through the process for managingprograms. This process requires the review of program relatedoperating experience by the program owner.

Both of these processes review operating experience from bothexternal and internal (also referred to as in-house) sources.External operating experience may include such things as INPOdocuments (e.g., SOERs, SERs, SENs, etc.), NRC documents(e.g., GLs, LERs, INs, etc.), General Electric documents (e.g.,RCSILs, SILs, TILs, etc.), and other documents (e.g., 1OCFR Part21 Reports, NERs, etc.). Internal operating experience mayinclude such things as event investigations, trending reports, andlessons learned from in-house events as captured in programnotebooks, self-assessments, and in the 10 CFR Part 50, AppendixB corrective action process.

Demonstration that the effects of aging are effectively managed isachieved through objective evidence that shows that Closed CycleCooling Water program is being adequately managed in piping,piping components, piping elements and heat exchangers. Thefollowing examples of operating experience provide objectiveevidence that the Closed Cycle Cooling Water program is effective

D. Ashley-PBB1.14 CCCW Rev.O.doc PageP30


in assuring that intended function(s) will be maintained consistentwith the CLB for the period of extended operation:

1) In 2000, UT measurements were taken on RBCCW piping.The results showed that there was extensive pitting on theoutside of the piping. The lowest reading was 0.1 97 withother readings well above 0.300". The minimum wallthickness for the pipe is 0.100" for 8" pipe and 0.1 25" for 10"pipe. Therefore the actual thickness readings were wellabove that needed for minimum wall considerations. Thisexample provides objective evidence that significantdegradation of the RBCCW piping is not occurring from theinside (CCCW) of the piping and that minimum wall thicknessis being maintained. (Reference: CAP 02000-1408)

2) In 2001 Water Technology Consultants, Inc performed anassessment of the CCCW Program. The results showed thatthe RBCCW and TBCCW testing frequency, per siteprocedures, were met. However, the EDGCCW monitoringdid not meet the specified quarterly frequency. (Reference:Closed Cooling Water Chemistry Assessment OysterCreek Nuclear Generating Station - Final ReportSeptember 6, 2001) Conversely, since 1999 analysis of pH,azole (Benzotriazole), and nitrite have never entered anaction level per the most recent EPRI guidelines. Additionallythe closed cycle cooling water is replaced every 2 years. Thisensures that corrosion prevention is adequate in the EDGclosed cycle cooling water system.

3) The Water Technology Consultants, Inc assessment reportalso documented that there have been some pipe wallthickness measurements performed in the RBCCW andTBCCW systems and based on this testing there have beenno indications of pipe wall loss. (Reference: Closed CoolingWater Chemistry Assessment Oyster Creek NuclearGenerating Station - Final Report September 6, 2001)

4) In 2002 Oyster Creek increased their desired molybdaterange in all of the closed cycle cooling water systems from 50-125 ppm to 200-1000 ppm. This enabled Oyster Creek toalign with industry best practices. This example providesobjective evidence that the Closed Cycle Cooling Waterprogram is continually monitoring the system parameters andadjusting the program in an effort to improve the program.

5 D Asley- BD 13.1.14 CCCW Rev.OwdCos~cy D. Asly PBD B..1�CCCW: R.O.c A=-+ .=:: _,Page 311


5) In 2004, the pH in the TBCCW system decreased outside theAction Level 1 range for pH. A caustic add was made thatreturned pH back in spec within the acceptable time periodfor correcting an Action Level 1 CCW limit. This exampleprovides objective evidence that the Closed Cycle CoolingWater program is effective in monitoring system parametersand returning any adverse trends to within the levels specifiedin EPRI 1007820 in a timely manner.

The operating experience of the Closed Cycle Cooling Waterprogram did not show any adverse trend in performance. Inaddition to mitigating loss of material and buildup of deposits bymaintaining water chemistry, Oyster Creek monitors the RBCCW,TBCCW and EDGCW for microbiological growth (total bacteriacolonies) in accordance with EPRI1 007820, "Closed Cooling WaterChemistry Guidelines." To date there have been no adverse trendsassociated with microbiological growth in closed cycle cooling watersystems. Problems identified would not cause significant impact tothe safe operation of the plant, and adequate corrective actionswere taken to prevent recurrence. The Oyster Creek Closed CycleCooling Water program has identified when monitored parametersare outside of acceptable ranges and has and returned anyadverse trends to within the levels specified in EPRI 1007820 in atimely manner. Additionally the program is continually monitoringthe system parameters and adjusting the program in an effort toimprove the Closed Cycle Cooling Water program. There issufficient confidence that the implementation of the Closed CycleCooling Water program will effectively determine loss of materialand reduction of heat transfer.

3.10 Conclusion

The Oyster Creek Closed Cycle Cooling Water aging managementprogram is credited for managing loss of material and reduction ofheat transfer for the systems, components, and environments listedin Table 5.2. The Oyster Creek Closed Cycle Cooling Waterprogram's elements have been evaluated against NUREG-1 801 inSection 3.0. Program exceptions have been identified in Section2.3. No program enhancements were identified in Section 2.4.The implementing documents for this aging management programare listed in Table 5.1. The relevant operating experience hasbeen reviewed and a demonstration of program effectiveness isprovided in Section 3.10.

Based on the above, the continued implementation of the Oyster

D.Ashley-PBD B.1.14 CCCWRev.O.doc Paae 32 1

_RP3 B. .14 CW ev:9o 'Pa'ge'3A2 :


Creek Closed Cycle Cooling Water aging management programprovides reasonable assurance that loss of material and reductionof heat transfer will be adequately managed so that the intendedfunctions of components within the scope of license renewal will bemaintained during the period of extended operation.

4.0 REFERENCES

4.1 Generic to Aging Management Programs

4.1.1 10 CFR 50, Appendix B, QualityAssurance Criteria forNuclear Power Plants and Fuel Reprocessing Plants

4.1.2 10 CFR 54, Requirements for Renewal of OperatingLicenses for Nuclear Power Plants

4.1.3 NUREG-1 800, Standard Review Plan for Review of LicenseRenewal Applications for Nuclear Power Plants, Revision 1,dated September 2005

4.1.4 NUREG-1801, Generic Aging Lessons Leamed (GALL)Report, Revision 1, dated September 2005

4.2 Industry Standards

4.2.1 EPRI 1007820, Closed Cooling Water Chemistry Guideline,Revision 1

4.3 Oyster Creek Program References

4.3.1 OC-4, Program Plan Oyster Creek Generating StationInservice Pressure Testing Program Fourth InspectionInterval

4.3.2 Oyster Creek Technical Specifications Sections 3.7.C and4.7.A and 4.3.C.

4.3.3 Water Technology Consultants, Inc., C6oed Cdoling WatehChemistry Assessment Oyster Creek Nuclear 3eneratingStation - Final Report September 6, 2001

5.0 TABLES

5.1 Aging Management Program Implementing Documernts

Procedure Procedure Title Commitment StatusNumber No.

:Fd-,"--,,-,"--"D",",l,, CCCW kev.0.' gres S ca Pae {I D. Ashley - PBD B.1 .14 CCCW Rev.O.doc Paqe 33 I

7----Oyster CreekLicense Renewal ProjectClosed Cycle Cooling Water Systems


309.1.1 Turbine Building 330592.14.13 AGO/ASClosed Cooling GWater RoutineEvolutions

341 Emergency Diesel 330592.14.08 ACC/ASGenerator GOperation

636.1.010 Diesel Generator 330592.14.12 ACC/ASInspection (24) G

636.4.003 Diesel Generator 330592.14.05 ACG/AS#1 Load Test G

636.4.013 Diesel Generator 330592.14.15 ACC/AS#2 Load Test __G

642.4.001 RBCCW Inservice 330592.14.11 ACC/ASTest G

CY-OC-120-1 10 Chemistry Limits 330592.14.14 ACC/ASand Frequencies G

CY-AA-120-400 Closed Cooling 330592.14.10 ACC/ASWater Chemistry G

ER-AA-2030 Conduct of Plant 330592.14.17 ACC/ASEngineering GManual -

PM00120M Inspect, clean & 330592.14.16 ACC/ASreplace anodes in Gthe TBCCW HX

PM00184M Clean HX and 330592.14.02 ACC/ASReplace Anodes Gin the HeatExchanger(TBCCW)

PM00189M Inspect, clean & 330592.14.07 ACC/ASreplace anodes in Gthe RBCCW HX

PM00209M Inspect, clean & 330592.14.06 ACC/ASreplace anodes in Gthe RBCCW HX

PM86104A Replace #2 EDG 330592.14.03 ACC/ASWater-Pump G

PM86104A Replace #1 EDG 330592.14.04 ACC/ASWater Pump G

PMVTO01 5 VT-2 Inspection of 330592.14.01 ACC/ASPipe & comps on GRB3CCW

L D. 0Ashlev - PBD B. 1. 14 iCCCW Rev.O.doc Page 34 I[D. Ashley- PBD -1 4 CCC- RevO-doc Paa 341 - -



5.2 Aging Management Review Results

SSC Name Structure andlor Component Material Environment Aging EffectEmergency Diesel Generator Temperature Control Manifold Carbon and low alloy steel Closed Coaling Water Loss of Materialand Auxiia System _ WateCoolin ternalJ)_____(I e a _

Emergency Diesel Generator Sensor Element (Temperature Stainless Steel Closed Cooling Water Loss of Materialand Auxiliay SystemControl Manifold) ____ ____ I__ Qnte_ __ _

Emergency Diesel Generator Sensor Element (Temperature Brass Closed Cooling Water Loss of Materialand Auxiliary System Control Manifold) (Internal)Emergency Diesel Generator Tanks (immersion Heater) Carbon and low alloy steel Closed Cooling Water Loss of Materialand Auxiliary System (Iteral)Emergency Diesel Generator Tanks (Water Tank) Carbon and low alloy steel Closed Cooling Water Loss of Materialand Auxiliary System Internal)Emergency Diesel Generator Heat Exchangers (Radiator) Brass (tubes) Closed Cooling Water Loss of Materialand Auxil tern_ _ ntemrn!)Emergency Diesel Generator Heat Exchangers (Radiator) Brass (tube side components) Closed Cooling Water Loss of Materialand Auxiliary System (f_ ntemali _

Emergency Diesel Generator Heat Exchanger (Lube Oil Brass (tubes) Closed Cooling Water Loss of Materialand Auxiliary System K Cooler) (Internal)Emergency Diesel Generator Thermowell Brass Closed Cooling Water Loss of Materialand Auxiliary System (intemal)Emergency Diesel Generator Restricting Orifice Brass Closed Cooling Water Loss of Material

X and Auxiliary System l _ $nterai)Emergency Diesel Generator Restricting Orifice Brass Closed Cooling Water Loss of Material_d Auxiary System _ (Inteal)Emergency Diesel Generator Valve Body Stainless Steel Closed Cooling Water Loss of Materialand Auxiliay System $ (Internal)Emergency Diesel Generator Piping and fittings Stainless Steel $ Closed Cooling Water Loss of Materialand Auxiliary System _ (Internal)Emergency Diesel Generator Sensor Element (Temperature Carbon and low alloy steel Closed Cooling Water Loss of Materialand Auxiliary System Control Manifold) (Interal)

E Emergency Diesel Generator Valve Body Brass Closed Cooling Water Loss of Materialand AuxiliaSy stem i 'Internal)

I Emergency Diesel Generator Piping and fittingsL t and __I_ _Syte

Carbon and low alloy steel Closed Cooling WaterI _ Llnte maaL !

Loss of Material I

D. Ashty- PBD B.1.14 CCCW Rev.O.doc ~1 :W: e:W _(S 35} W - si- .= - _ I .. :; . I - = ' ' ' =="" *L-



Main Steam System

-s System

Process Sampling System

Coolers (Sample)

Thermowell

Piping and fittings

Stainless Steel (Tube SideComponents)CaStainless Steel

Carbon and low alloy steel

Closed Cooling Water(Extemal)Closed Cooling Water < 140F.(lnternaI ___

Closed Cooling Water < 140FlIntamal)

Loss of Material

Loss of Material

Loss of Material

Process Sampling System Pump Casing Carbon and low alloy steel Closed Coding Water < 140F Loss of Material(Intemal)

Process Sampling System Tanks (Reservoir) Carbon and low alloy steel Closed Cooling Water < 140F Loss of MaterialA _ (Intem al) _ _ _ __ _ _ _ _

Process Sampling System Piping and fittings Stainless Steel Closed Cooling Water < 140F Loss of Material__ _ __ __ ___ _ __tm __ _ _ na_ _A__

Process Sampling System Evaporator Copper Closed Cooling Water < 140F Loss of Material

Process Sampling System Valve Body Stainless Steel Closed Cooling Water < 140F Loss of Material(Intemal)

Process Sampling System Valve Body Carbon and low alloy steel I Closed Cooling Water < 140F Loss of Material_ (Intemal)

Reactor Building Closed Thermowell Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water System __ (Intemal)Reactor Building Closed Pump Casing (Chemical Feed Carbon and low alloy steel TClosed Cooling Water Loss of Material

.Cooling Water System _ I Pump) _emai

Reactor Building Closed Gauge Snubber Stainless Steel Closed Cooling Water <140F Loss of MaterialY _W-ater nteal)

Reactor Building Closed Gauge Snubber Stainless Steel Closed Cooling Water <140F Loss of MaterialCooling Water System j (Intemal)Reactor Building Closed Filter Housing Stainless Steel Closed Cooling Water <14OF Loss of MaterialCooling Water System (Intemal)Reactor Building Closed Level Glass Copper Alloy Closed Cooling Water Loss of MaterialCooling Water Sstern _ ____ _____ _llntemalReactor Building Closed Tanks (Chemical Mixing Tank) Carbon and low alloy steel Closed Cooling Water Loss of Material

ECoolirg Water Systm _____I(n!LalReactor Building Closed Flow Element Stainless Steel Closed Cooling Water <IAOF Loss of MaterialCooling Water System _ Vav Bdqntemal)_Reactor Building Closed ae Bd Carbon and lw alloy steel Closed Cooling Water Loss of Material

ool W ystem S (InteSnal)Reactor Building Closed Valve Body Stainless Steel Clsed Coding Water <140F Loss of Material

W (Ct oo r Is

[D. AsIey - BD 1. 14 CCCW Rev.O.doc Page 361''=i'-Eni"tOSY:..:::= : : : :={i.................................................................. -- W- ~i 4.A.................IflU: -- .1 y:--,EE,, i--, ................... ,=sc



Reactor Building Closed Valve Body Copper Alloy Closed Cooling Water Loss of MaterialCooling Water m _y _ __ _ _ _-. -. __ _ _ _ _ ___ fin__ma _ _ _ __IReactor Building Closed Valve Body Stainless Steel Closed Cooling Water <140F Loss of MaterialCooling Water System __ _ _____ _ (lntemal)_Reactor Building Closed Valve Body Carbon and low alloy steel Closed Cooling Water Loss of Material

Reactor Building Closed Piping and fittings Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water Syste_Reactor Building Closed , Thermowell Stainless Steel Closed Cooling Water <140F Loss of MaterialCooling Water (t _internal)

Reactor Building Closed Piping and fittings Stainless Steel Closed Cooling Water < 140F Loss of MaterialCooling Water Systemrn _ _ _______ ___ _ __ (!ntemnalL -_ ______

Reactor Building Closed Piping and fittings Carbon and low alloy steel Closed Cooling Water Loss of MaterialCog e Systemn Int2_ -

Reactor Building Closed Coolers (Sample) Copper Closed Cooling Water Loss of MaterialCooling Water Syste (Internal)Reactor Building Closed Piping and fittings Stainless Steel Closed Cooling Water <140F Loss of MaterialCooling Water Systern (Internal)Reactor Building Closed Coolers (Core Spray Pump Copper Closed Cooling Water Loss of MaterialCooling Water System I Room) I_(Internal)Reactor Building Closed XCoolers (Tunnel) Copper Closed Cooling Water Loss of MaterialCool n Water System ___ _ _I ___ _ (Internal_Reactor Building Clsed Coolers (Post Accident Copper Closed Cooling Water Loss of MaterialC oinoWate rstem Sa a __i_ _ _ Lniml)Reactor Building Closed Coolers (Shutdown Cooling Copper (Seal Cooler Tubes) Closed Cooling Water Reduction of HeatCooling Water System Pumps) ( 'External) TransferReactor Building Closed Coolers (Shutdown Cooling Cast Iron (Bearing Housing Closed Cooling Water Reduction of HeatCoolina Water Svster Pumps) Cooler) i(lntemal) TransferReactor Building Closed Coolers (Shutdown Cooling Copper (Seal Cooler Tubes Closed Cooling Water Loss of MaterialCooling aten System _ Pumps) _ Tube Side Componentsq)__ [(ExemaI)Reactor Building Closed Heat Exchangers (Drywell Carbon Steel (Covers) Closed Cooling Water Loss of MaterialCooling ter System _ Cast Iron(Bearin usino Tf ate ial)Reactor Building Closed Coolers (Shutdown Cooling Cast Iron (Bearing Housing Closed Cooling Water Loss of MaterialCooling Water System _ _ Pumps) Cooler) !Iteme1)

Cooling Water System Equipment Drain Tank) Plates) (Internal)Reactor Building Closed Coolers (Cleanup Pre-coat Carbon Steel (Shell Side Closed Cooling Water Loss of MaterialCooling Water System I Pumn) ens (Internal) _

D. Ashley - PBD B.1.14 CCCW Rev.O.doc Page 37 1



Reactor Building Closed Coolers (Drywell Cooling Copper Closed Cooling Water Loss of MaterialCooling Water System _ _Units) _ _ __ ___ ___Reactor Building Closed Coolers (Cleanup Recirc. Cast Iron (Tube Side Closed Cooling Water Loss of MaterialColingyWater System Pumps Lube Oi) Components) (Intemal)Reactor Building Closed Coolers (Cleanup Auxiliary Cast Iron (Bearing Housing Closed Cooling Water Loss of MaterialCoolin WaterSyste Cooler) ntemal)Reactor Building Closed Coolers (Cleanup Auxiliary Carbon Steel (Pedestal Closed Cooling Water Loss of MaterialCooling Water System Pump) Cooler) (Intemal)Reactor Building Closed Piping and fittings Cast Iron Closed Cooling Water Loss of MaterialCooling Water System (Intemal)Reactor Building Closed Coolers (Cleanup Auxiliary Stainless Steel (Seal Cooler) Closed Cooling Water < 140F Loss of MaterialCo-ling Water Sy stemInte mal) ___________

Reactor Building Closed Coolers (Shutdown Cooling Carbon Steel (Seal Cooler Closed Cooling Water Loss of MaterialCo ig Water System i Pumps _ _ Shell Side Components) Intemal)

Reactor Building Closed Heat Exchangers (Fuel Pool Carbon Steel (Tubes) Closed Cooling Water Reduction of HeatlingWatr System Cooling) (Extemal) Transfer

Reactor Building Closed Thermowell Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water System (Intemal)Reactor Building Closed Valve Body Copper Alloy Closed Cooling Water Loss of MaterialCoolin Water System (Inteal)Reactor Building Closed Thermowell Stainless Steel Closed Cooling Water < 140F 4Loss of MaterialCooling Water System __ner_ __ __ _ E_

Reactor Building Closed Rupture Disks Aluminum Closed Cooling Water 1 Loss of MaterialCoolng Waterystma iReactor Building Closed - rPump Casing (RBCCW Cast Iron Closed Cooling Water Loss of MaterialCooling Water System ~Pumps) (Intemal) IReactor Building Closed Tanks (RBCCW Surge Tank) Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water System (Intemal)Reactor Building Closed Heat Exchangers (ShutdownC! eCool Q__ ___ _Reactor Building Closed Coolers (Containment SprayCooling WaterSystem _ Pump Room)Reactor Building Closed | Heat Exchangers (ShutdownCooling Water System I CoolingReactor Building Closed Heat Exchangers (Fuel PoolCoolina Water Svstem Coolina)

Stainless Steel (Tubes)

Copper

Closed Cooling Water

Cl toe d o ol iClosed Cooling Water_(Intemnal) _ ___Closed Cooling Water(Intemal)Closed Cooling Water(Intemnal)

Reduction of HeatTransferLoss of Material

1 Loss of MaterialCarbon Steel (Shell SideComponents)Carbon Steel (Shell SideComoonents)

ILoss of Material

Reactor Building Closed Heat Exchangers (Fuel PoolCooling WaterSstem C OIna)

Carbon Steel (Tubes) Closed Cooling WaterI(Exteal)

------- FLosis of MaterialI

_ 8s _E

D.Ash!ey: PBD B.1 .14CCCWRev.O.doc Pacie 38 �

Lp /B .1 CCCW Rev.O.doc Paqe 38'e



Reactor Building Closed Heat Exchangers (Augmented Stainless Steel (Plates) Closed Cooling Water Reduction of HeatCoaling Water System ____ Fuei PoolCoolm ing) _ __ .ntemal) __ ___.Transfer

Reactor Building Closed Strainer Body Carbon and low alloy steel Closed Cooling Water Loss of MaterialCoolina Water System _ ___ _ __ _. ___ _ (Intemal) _ _ -Reactor Building Closed Heat Exchangers (Augmented Stainless Steel (Plates) Closed Cooling Water < 140F Loss of MaterialCooling Water System Fuel Pool Coolig) (nteaReactor Building Closed Heat Exchangers (Augmented Carbon Steel (Covers, Closed Cooling Water Loss of MaterialCooling Water System Fuel Pool Cooling) Nozzles) (Intemal)Reactor Building Closed Heat Exchangers (Cleanup Carbon Steel (Shell Side Closed Cooling Water Loss of Material

Coolng aterSysem on-Regneative) Components) ltm)__________Reactor Building Closed Heat Exchangers (Shutdown Stainless Steel (Tubes) Closed Cooling Water <14OF Loss of MaterialCodng WaterSystem _ Cooln _ _ __ ____ __ (Extemal)Service Water System feat Exchangers (RBCCW) Titanium (Tubes) Closed Cooling Water Loss of Material

I __ _ _ __ ____ (Extemal)Service Water System Heat Exchangers (RBCCW) Carbon Steel (Shell Side Closed Cooling Water Loss of Material

_ _ Components) (Intemal)Turbine Building Clsed . Flw Glass Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling W ater System l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ j (Intemal) _ _ _ _ _ _ _ _ _

Turbine Building Closed Coolers (Control Room AC) Carbon Steel - Shell Side jClosed Cooling Water Loss of MaterialC Components (lntemal)Turbine Building Closed . Tanks (Surge, Chemical Carbon and low alloy steel Closed Cooling Water Loss of Material_ooli Water System Mixing, Closed Cooling Water} (Intemal) _

Turbine Building Closed auge Snubber Stainless Steel . Closed Cooling Water < 140F Loss of Material_qCooiqte System .intemal) I

rTurbine Building Closed Flow Element Carbon and low alloy steel Closed Cooling Water Loss of MateriatCooling Water System (Internal) l _l

Turbine Building Closed Filter Housing Stainless Steel Closed Cooling Water < 140F Loss of MaterialCooling Water System (Internal)Turbine Building Closed Valve Body - Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooing Water S atm _ Inte nal)Turbine Building Closed Flexible Connection I Stainless Steel Closed Cooling Water < 140F Loss of MaterialCooling Water System - a (1nternal LTurbine Building Closed Thermowell Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water Sytm _ __ (Inteal) o MateriaTurbine Building Closed Strainer Body Carbon and low alloy steel Closed Cooling Water Loss of Material

Coolna ate Svtem(Intemnal)Turbine Building Closed Heat Exchangers (TBCCW) Carbon and low alloy steel - Closed Cooling Water t Loss of MaterialCooling Water System Shell Side Components (Internal) II

Lq D. Ahe BD B.1.14 CCCW Rev.O.doc Pwaq39[D. Ashley-PBD B.1 .14 CCCWRevO.doc Pacie 391


PBDAMP-B.1.14, Revision 0Page 39 of 40

Turbine Building Closed Level Glass Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water System __ ___ (lntemalj __ _Turbine Building Closed Piping and fittings Galvanized Steel Closed Cooling Water Loss of MaterialCooling Water System_ ____rn aTurbine Building Closed Coolers (Service Air Carbon Steel - Shell Side Closed Cooling Water Loss of Material

Compressor C _ntTurbine Building Closed Valve Body Copper Alloy Closed Cooling Water Loss of MaterialCooling Water System (Internal)Turbine Building Closed Piping and fittings Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water System (Internal)Turbine Building Closed Piping and fittings Stainless Steel Closed Cooling Water < 14_F Loss of MaterialCooling Water System_ ___ ___jn__ _ m ernal) ____Turbine Building Closed Coolers (Final Feedwater Stainless Steel - Shell Side Closed Cooling Water < 140F Loss of MaterialCoolin Water S FacilityL_ _ComTponents___ (Internal)Turbine Building Closed Coolers (Service Air Carbon Steel - Tube Side Closed Cooling Water Loss of MaterialCooling Water System Compressor InterCooler) Components (Internal)Turbine Building Closed Coolers (Service Air Carbon and low alloy steel Closed Cooling Water Loss of MaterialCooling Water Sstem ICompressor Cyinders)Turbine Building Closed Coolers (Reactor Recirculation Copper Alloy - Tube Side Closed Cooling Water Loss of MaterialCoi We te Pump M-G Sets) ] Components (Internal)Turbine Building Closed Coolers (Turbine Lube Oil) Carbon Steel - Tube Side Closed Cooling Water Loss of MaterialCooling Water System _ __i Components __ _ (Interal)Turbine Building Closed Coolers (Feedwater and Main Copper Closed Cooling Water Loss of MaterialCooling Water System Steam Sample} - _ _ intoTurbine Building Closed Pump Casing (TBCCW Cast Iron Closed Cooling Water Loss of MaterialCooling Water System Pumps, Chemical Feed Pump (Internal)Turbine Building Closed Valve Body Stainless Steel Closed Cooling Water < 140F Loss of MaterialCooling Water System (Internal)Turbine Building Closed Coolers (Thermal Control Unit) Carbon Steel - Shell Side Closed Cooling Water Loss of MaterialCooling Water System __I Comooents (ttemal)- _Turbine Building Closed Coolers (Condenser Vacuum Copper Alloy - Tube Side Closed Cooling Water Loss of MaterialCooig Water System __I ___ Comporwnts __ - In ternal) ITurbine Building Clsed Coolers (Condensate Pump Copper Alloy Closed Cooling Water Loss of MaterialCooling Water System Motor) _ _ (Internal)Turbine Building Closed Coolers (Feedwater Pump Copper Alloy -Tube Side Closed Cooling Water Loss of MaterialCooling Water System I Lube Oil) i Components (Internal)tTurbine Buiding Closed ICoolers (Stator Winding Carbon Steel - Tube Side Clsed Cooling Water Loss of Material

uid) Components (Internal)

,D. Ashley - PBD B.1.14 CCCW Rev.O.doc Page 40 t



Turbine Building Closed - Coolers (Hydrogen) Cast Iron - TubtCoolipg Water System ___ ComponentsTurbine Building Closed' Heat Exchangers (Generator Copper - Tube 'Cooling Water System Bus)p . ComponentsTurbine Building Closed Thermowell Stainless SteelConline Water Svster

e Side Closed Cooling Water Loss of Material_(nterna _ __

Side Closed Cooling Water Loss of Material.__ Intal _ _ __ _

Closed Cooling Water < 14OF Loss of Material(Internal)

ID . Ashley --PB bb .14 CCCW Re.d oc Pe41



6.0 ATTACHMENTS

6.1 LRA Appendix A

6.2 LRA Appendix B

[ D. PqD 3z ontr Sructures Rev. O.doc .Page 1

Oyster Creek PBD-AMP-B.1.32, Revision 0License Renewal Project Page 1 of 35RG 1.127, Inspection of Water-Control Structures Associated with NuclearPower Plants


PBD-AMP-B.1 .32

- Revision 0

RG 1.127, INSPECTION OF WATER-CONTROL STRUCTURESASSOCIATED WITH NUCLEAR POWER PLANTS

GALL PROGRAM XI.S7 - RG 1.127, INSPECTION OF WATER-CONTROLSTRUCTURES ASSOCIATED WITH NUCLEAR POWER PLANTS

Prepared By:

Reviewed By:



I

Revision History: IRevision Prepared by: Reviewed by: Program Approved by:

Owner,

0 A. Ouaou T.Quintenz S. Niogi Don Warfel

Date

I I I I -

D e -PWBD B.t~e,,,.32 Water Control Structures Rev. Od.oc Page 22WWW~~~~ --- ---W W@l.. '.'=WWWW ............. WWWW& .,,4RWW (.W2 ........................... 6:.WEW a



Rev. Number Reason for the Revision(s)0 Initial Issue

- - � - - - -_ -- ��_ -- , . _-- �� I--- � vl__ ,M- ",_ � � � - �. �_ 4 , - 6-, 1�1, Y�- ff - � -, . � �_ - , - � � - - - � - - - X - �__ , - -

E D. Ashlev - PBD B. 1.32 Water Control Structures Rev. O.doc Paa'e 31lI D. Ashley - PBD B.1 .32 Water Control Structures Rev. 0.doc Paae 31


TABLE OF CONTENTS


2.0 PROGRAM DESCRIPTION 52.1 Program Description 52.2 Overall NUREG-1801 Consistency 92.3 Summary of Exceptions to NUREG-1 801 92.4 Summary of Enhancements to NUREG-1 801 9

3.0 EVALUATIONS AND TECHNICAL BASIS 113.1 Scope of Program 113.2 Preventive Actions 133.3 Parameters Monitored or Inspected 133.4 Detection of Aging Effects 153.5 Monitoring and Trending 183.6 Acceptance Criteria 193.7 Corrective Actions 203.8 Confirmation Process 213.9 Administrative Controls 223.10 Operating Experience 223.11 Conclusion 27

4.0 REFERENCES 274.1 Generic to Aging Management Programs 274.2 Industry Standards 284.3 Oyster Creek Program References, 28

5.0 Tables 305.1 Aging Management Program Implementing 30Documents5.2 Aging Management Review Results 27

6.0 Attachments 356.1 LRA Appendix A6.2 LRA Appendix B

E U.' A~s'hIeyv -- PB-D B'.-1.'3-2Wa-ter C-ontrol-S'tr~u-ct'ur~e"s' Rev. O. doc 7...,.: ... =: A.:2:Page -4I D. Ashley - PBD B.1 .32 Water Control Structures Rev. O.doc Paae 4 1I I



1.1 Purpose

The purpose of this Program Basis Document is to document andevaluate those activities of the Oyster Creek RG 1 .127, Inspectionof Water-Control Structures Associated with Nuclear Power Plantsaging management program that are credited for managing loss ofmaterial, cracking, change in material properties, and loss of formfor components of the Intake Structure and Canal (Ultimate HeatSink), the Dilution Structure, the intake structure trash racks, andthe Fire Pond Dam as part of Oyster Creek License Renewal tomeet the requirements of the License Renewal Rule 10 CFR 54,"Requirements for Renewal of Operating Licenses for NuclearPower Plants."




* The review of Operating Experience to demonstrateprogram effectiveness;

* The identification of required program enhancements;and

* The identification of Oyster Creek documentsrequired for implementing the program

1.2 Methodology

The nuclear power plant License Renewal Rule 10 CFR 54,"Requirements for Renewal of Operating Licenses for Nuclear Power;Plants," describes the License Renewal process and providesrequirements'for the contents of License Renewal Applications. 10 CFR54.21 (a)(3) states:

"For each structure and component identified in paragraph (a)(1) of thissection, demonstrate that the effedts of aging willIe adequately managedso that the intended function(s) ill be maintained consistent with thei`Current Licensing Basis (CLB) for the period of ettended operation."

The NRC and the industry idehtifiect 10 program elements that are usefulin describing an aging management program and then demonstrating itseffectiveness. These program elements are described in Appendix A.1,

V b. Ashlev - PBD 13.1.32 Water Control Structures Rev. O.doc Page 5 I0. Ashley - PBD B.1 .32 Water Control Structures Rev. O.doc Paae 5 1I .- I


Section A.1.2.3 of the Standard Review Plan. NUREG-1 801 uses theseprogram elements in Section Xi to describe acceptable agingmanagement programs.

This Program Basis Document also provides a comparison of the creditedOyster Creek program with the elements of the corresponding NUREG-1801 Chapter Xl program XI.S7, Inspection of Water-Control StructuresAssociated with Nuclear Power Plants. Project Level Instruction PLI-8"Program Basis Documents" prescribes the methodology for evaluatingAging Management Programs. An evaluation of Oyster Creek's agingmanagement program criteria or activities to those of the NUREG-1 801program elements is performed and a conclusion is reached concerningconsistency for each individual program element. A demonstration ofoverall program effectiveness is made after all program elements areevaluated. Required program enhancements are documented. An overalldetermination is made as to consistency with the program description inNUREG-1 801.



NUREG-1 801:

a) Nuclear Regulatory Commission (NRC) Regulatory Guide (RG)1.127, Revision 1, "Inspection of Water-Control StructuresAssociated with Nuclear Power Plants, " describes anacceptable basis for developing an inservice inspection andsurveillance program for dams, slopes, canals, and other water-control structures associated with emergency cooling watersystems or flood protection of nuclear power plants. The RG1.127 program addresses age-related deterioration,degradation due to extreme environmental conditions, and theeffects of natural phenomena that may affect water-controlstructures. The RG 1.127 program recognizes the importance ofperiodic monitoring and maintenance of water-control structuresso that the consequences of age-related deterioration anddegradation can be prevented or mitigated in a timely manner.

b) RG 1.127 provides detailed guidance for the licensee'sinspection program for water-control structures, includingguidance on engineering data compilation, inspection activities,technical evaluation, inspection frequency, and the content ofinspection reports. Water-control structures covered by the RG1.127 program include concrete structures; embankmentstructures; spillway structures and outlet works; reservoirs;

Ofoc: Page 0 XI2.AsPley:,PBD.�.1�.3� Water Control Structures Rev. Q.doc Page6�


cooling water channels and canals, and intake and dischargestructures; and safety and performance instrumentation. RG1.127 delineates current NRC practice in evaluating inserviceinspection programs for water-control structures. The attributesof an acceptable aging management program (AMP) for licenserenewal are described below.

c) For plants not committed to RG 1.127, Revision 1, agingmanagement of water-control structures may be included in theStructures Monitoring Program (XI.S6). Even if plant iscommitted to RG 1.127, Revision 1, aging management ofcertain structures and components may be included in theStructures Monitoring Program (XI.S6). However, detailspertaining to water-control structures are to incorporate theattributes described herein.

Oyster Creek:

a) The Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants program isan existing program that will be enhanced to requireinspection of water control structures identified in the currentlicensing basis (CLB) that are in scope of license renewalconsistent with the requirements of NRC RG 1.127Inspection of Water-Control Structures Associated withNuclear Power Plants. These structures Include the IntakeStructure and Canal (Ultimate Heat Sink), Fire Pond Dam,and intake structure trash racks. The scope of the programwill also include the Dilution Structure, which is not identifiedin the CLB as a water control structure, but determined to bepart of the intake canal (Ultimate Heat Sink) boundary forlicense renewal. Structural components and commodities ofthe structures that are monitored under the existing programinclude reinforced concrete members, earthen water controlstructures (intake canal, embankments), and variouscomponents of the Fire Pond Dam (Reference: 125.6)

The Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants agingmanagement program addresses age-related deterioration,degradation due to extreme environmental conditions, andthe effects of natural phenomena that may affect the safetyfunction of the water control structures (Reference: 125.6,ABN-31 paragraph 3.6.11(G); ABN-38 paragraph 3.3).Elements of the program are designed to detectdegradations and take corrective actions to prevent a loss of

[ D. Ashey- -1P3BD B.1.32 Water Control Structures Rev. O.doc Page- .ixI D. Ashley- PBD B.1 .32 Water Control Structures Rev. 0.doc Pace TI


an intended function.

The Fire Pond Dam is a small earthen dam with timberspillway designed to impound fresh water used primarily forfire protection. The dam is classified hazard category IlIl (lowhazard) and subject to periodic inspections to satisfy therequirements of New Jersey Dam Safety Standards, N.J.A.C7:20-1.1 et seq (Reference: 4.3.13). Inspection activities,technical evaluation, inspection frequency, and the contentof the inspection report are consistent with the requirementsof RG. 1.127 guidance. The dam is not currently addressedin the Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants agingmanagement program implementing procedures. The damhowever is inspected to ensure public safety consistent withNRC RG 1.127 requirements. The program implementingprocedure (Reference: 125.6) will be enhanced to includemonitoring of the dam.

b) The Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated With Nuclear Power Plants isimplemented through the Oyster Creek StructuresMonitoring aging management program B.1.31. Theprogram provides guidance for inspecting the IntakeStructure and Canal (Ultimate Heat Sink), including earthenwater control structures (intake canal, embankments), andthe Dilution Structure (Reference: 125.6 paragraph 2.0).The enhanced program will provide additional guidance asdescribed in section 2.4 to ensure consistency with NUREG-1801, Program Xl.S7, Inspection of Water Control StructuresAssociated With Nuclear Power Plants.

Safety and performance instrumentation such as seismicinstrumentation, horizontal and vertical movement 2

instrumentation, uplift instrumentation, and otherinstrumentation described in RG 1.127 are not incorporatedin the design of Oyster Creek water control structures,! Thusinspection activities related to safety and performanceinstrumentation are not applicable, and are not specified inthe implementing documents.

Inspections of water control structures, other than the FirePond Dam, are conducted by or under the direction ofqualified engineers experienced in the investigation, design,construction, and operation of the structures. A professional

(

D. Ashley- PBD B.1 .32 Water Control Structures Rev. O.doc Paae 8 1D. AsB~y 13 ater Conrol Str es Rmev.OJ ''Page 81I


engineer licensed to inspect dams conducts inspection ofthe dam. Inspections are conducted systemtically usingchecklists and other documents as required to minimize thepossibility of overlooking significant features (Reference:125.6 paragraph 7, Attachment 125.6-1; 4.3.13).Technical evaluations are performed if observeddegradations have the potential for impacting the intendedfunction of the water control structures. Inspectionsfrequency is every 4 years except for submerged structures,which are inspected when the structures are dewatered.The program will be enhanced as described in Section 2.4 toprovide additional assurance that age related degradationsare detected and corrected before a loss of an intendedfunction.

c) The Oyster Creek original design did not commit to therequirements of RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants. Howeverin response to NUREG-0822, Integrated Plant SafetyAssessment Systematic Evaluation Program (SEP) Topic III-3.C, Oyster Creek evaluated water control structuresconsistent with the requirements of RG 1.127, Inspection ofWater-Control Structures Associated with Nuclear PowerPlants, and presented to the NRC the evaluation results andthe proposed Oyster Creek RG. 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants.surveillance program. In a letter dated June 24, 1982, theNRC provided the results of its review and comments on theproposed surveillance program This letter and NUREG-1382, Safety Evaluation Report related to the full-termoperating license for Oyster Creek Nuclear GeneratingStation (Reference: 4.3.18; 4.32) formed the basis for theexisting Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants agingmanagement program. Elements of the program have beenincorporated in the Oyster Creek Structures Monitoringaging management program; except for the Fire Pond Dam.

The Fire Pond Dam is currently inspected under the NewJersey Dam Safety Standards, N.J.A.C 7:20-1.1 et seq. Thedam inspection will be administered under the Oyster CreekRG 1.127, Inspection of Water-Control StructuresAssociated with Nuclear Power Plants aging managementprogram for the period of extended operation.

D.bAshly: LPBD B.1 .32 Water Control Structures Rev. O.doc Page9


2.2 Overall NUREG-1 801 Consistency

The Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants is consistent withNUREG-1 801 aging management program XI.S7, Inspection ofWater-Control Structures Associated with Nuclear Power Plants,with exceptions and enhancements described below.


The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants takes exceptionto the inspection frequency specified in NUREG-1 801 XI.S7, RG1.127, Inspection of Water-Control Structures Associated withNuclear Power Plants. This exception is applicable only tosubmerged structures. Technical basis for this exception isexplained in Section 3.4 below. This is a new exception notpreviously identified in the LRA


The existing Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants agingmanagement program is found to be adequate to support theextended period of operation with following enhancements.

• The program will provide for monitoring of submergedstructural components and trash racks.

* Parameters monitored will be enhanced to include change inmaterial properties, due to leaching of calcium hydroxide,and aggressive chemical attack.

* Add the requirement to inspect steel components for loss ofmaterial, due to corrosion

* Add the requirement to inspect wooden piles and sheetingfor loss of material and change in material properties.

* The program will provide for periodic inspection ofcomponents submerged in salt water (Intake Structure andCanal, Dilution structure) and in the water of the fire ponddam.

* The program will be enhanced to include periodic inspectionof the Fire Pond Dam for loss of material and loss of form.

* The program will be enhanced to require performing abaseline inspection of submerged water control structures

D. Ashley- PBD B.1.32 Water Control Structures Rev. 0.doc Page 10.


prior to entering the period of extended operation. A secondinspection will be performed 6 years after this baselineinspection and a third 8 years after the second. After eachinspection an evaluation will be performed to determine ifthe identified degradations warrant more frequentinspections or corrective actions. This constitutes a newenhancement not previously identified in the LRA.

[ D.- As'hley`^- -PB"D' B-.1.3-20~W~a~t-e-rC~ont'rolI St ructfu~res _R-ev. O. doc Page 1 1 iJ_I -- X_ - -


3.0 EVALUATIONS AND TECHNICAL BASISNote

This section is organized by quoting the relevant NUREG-1 801 ChapterXl program element (September 2005 version) followed by the relatedOyster Creek program attributes and a conclusion of the comparison.Where applicable, the NUREG-1801 program element was separatedinto logical sub-elements and addressed accordingly.



NUREG-1 801:

a) RG 1.127 applies to water-control structures associated withemergency cooling water systems or flood protection of nuclearpower plants.

b) The water-control structures included in the RG 1. 127 programare concrete structures; embankment structures; spillwaystructures and outlet works; reservoirs; cooling water channelsand canals, and intake and discharge structures; and safety andperformance instrumentation.

Oyster Creek:

a) The Oyster RG 1.127, Inspection of Water-Control StructuresAssociated with Nuclear Power Plants applies to water controlstructures associated with emergency cooling water system.The program will be enhanced to include the Fire Pond Dam.There are no water control structures that are credited for floodprotection.

b) Water control structures in scope of license renewal areincluded in the scope Oyster Creek RG. 1.127, Inspection ofWater-Control Structures Associated with Nuclear Power Plantsaging management program. These structures are the IntakeStructure and Canal (Ultimate Heat Sink), the Dilution Structure,and the intake structure trash racks. Structural componentsand commodities of the structures that are monitored under theexisting program include reinforced concrete members, andearthen water control structures (intake canal, embankments.The enhanced program will include the Fire Pond Dam and its

DBD B.1.32 Water Control Structures Rev. o.doc e12


various components, including the spillway, and embankments.

There are no safety and performance instrumentation such asseismic instrumentation, horizontal and vertical movementinstrumentation, uplift instrumentation, and otherinstrumentation described in RG 1.127 in the scope of OysterCreek RG 1.127, Inspection of Water-Control StructuresAssociated With Nuclear Power Plants aging managementprogram. These instrumentations are not incorporated in thedesign of Oyster Creek water control structures.

The Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants agingmanagement program manages the aging effect of loss of material,cracking, change in material properties, and loss of form for watercontrol structures, components, and environments listed in Table5.2. Intake structure trash racks are not included in Table 5.2; butthe trash racks are included with components monitored under theOyster Creek Structures Monitoring aging management program.The implementing documents for this aging management programare listed in Table 5.1 and are described throughout the individualprogram element discussions. The commitment numbers underwhich these implementing documents are being revised arecontained within the listings in Table 5.1.

Excentions to NUREG-1 801, Element 1:

None.

Enhancements to NUREG-1801. Element 1:

* The program will provide for monitoring of submergedstructural components and trash racks.

* The program will provide for periodic inspection ofcomponents submerged in salt water (Intake Structure andCanal, Dilution structure) and in the water of the Fire PondDam.

* The program will be enhanced to include periodic inspectionof the Fire Pond Dam for loss of material and loss of form.


This element is consistent with NUREG-1 801 Program, Xl.S7,Inspection of Water-Control Structures Associated with NuclearPower Plants, Element 1, Scope of Program, with enhancements

I I 11 I �- , , , ", r 11 , 1, 11 ...I.. ..... 11-111, " ',

BD .1.3 Water Control ctures ev. O.doc-D. Ashley- PBD BA .32 Water ControlIStructures Rev. O oc Pag e 13I



NUREG-1 801:

No preventive actions are specified; RG 1.127 is a monitoringprogram.

Oyster Creek:

The Oyster Creek RG 1.127, Inspection of Water-ControlStructures aging management program, specifies no preventiveactions. The program is a condition monitoring programestablished to detect age related degradations and deteriorationsdue to extreme environmental conditions, and the effects of naturalphenomena that may affect the water control structures.


None.


None.


This element is consistent with NUREG-1801, XI.S7, Inspection ofWater-Control Structures Associated with Nuclear Power Plants,Element 2, Preventive Actions.


NUREG-1 801:

a) RG 1.127 identifies the parameters to be monitored andinspected for water-control structures. The parameters varydepending on the particular structure. Parameters to bemonitored and inspected for concrete structures includecracking, movements (e.g., settlement, heaving, deflection),conditions at junctions with abutments and embankments,erosion, cavitation, seepage, and leakage.

b) Parameters to be monitored and inspected for earthenembankment structures include settlement, depressions, sinkholes, slope stability (e.g., irregularities in alignment andvariances from originally constructed slopes), seepage, properfunctioning of drainage systems, and degradation of slope

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Pa Ie 14 i^t;,,,lEL.=ffiMI'>"'SS'(

D. Ashley - PBD B.1 .32 Water Control Structures Rev. 0.doc PaQe 14�


protection features.

c) Further details of parameters to be monitored and inspected forthese and other water-control structures are specified in SectionC.2 of RG 1.127.

Oyster Creek:

a) Parameters monitored/inspected for reinforced concretecomponents include loss of material due to various agingmechanisms, including erosion and cavitation, cracking due tovarious aging mechanisms including settlement, and change inmaterial properties due to leaching of calcium hydroxide. Steelcomponents associated with earthen water control structures(intake canal, embankments), Fire Pond Dam, and trash racksare monitored for loss of material due to pitting and corrosion.Wooden components are monitored/inspected for loss ofmaterial and change in material properties. Slopes for earthenwater control structures at junction with abutments aremonitored for loss of material and loss of form (cracks,sinkholes, erosion, and slope instability).

b) Parameters monitored and inspected for earthen water controlstructures include settlement, depressions, sink holes, slopestability (e.g., irregularities in alignment and variances fromoriginally constructed slopes), and loss of slope protection liner.These parameters are considered loss of material and loss ofform. Earthen water control structures have no drainagesystems, and thus monitoring of drainage systems is notapplicable.

c) Details of parameters monitored are consistent with theguidance specified in Section C.2 of RG 1.127.


None.


* Parameters monitored for concrete will be enhanced toinclude change in material properties, due to leaching ofcalcium hydroxide, and aggressive chemical attack.

* Parameters monitored will include inspection of steelcomponents for loss of material due to corrosion and pitting.

* Parameters monitored will include inspection of wooden-piles and sheeting for loss of material and change in

P D. Ashlev - PBD B.1.32 Water Control Structures Rev. O.doc Page4 15~'D. Ahle - BD B1 .2 Wter ontol trucure Re. O~oc aae15


material properties.


This element is consistent with NUREG-1 801, XI.S7, Inspection ofWater-Control Structures Associated with Nuclear Power Plants,Element 3, Parameters Monitored or Inspected, withenhancements.


NUREG-1 801:

a) Visual inspections are primarily used to detect degradation ofwater-control structures. In some cases, instruments have beeninstalled to measure the behavior of water-control structures.

b) RG 1.127 indicates that the available records and readings ofinstalled instruments are to be reviewed to detect any unusualperformance or distress that may be indicative of degradation.

c) RG 1.127 describes periodic inspections, to be performed atleast once every five years.

d) Similar intervals of five years are specified in ACI 349.3R forinspection of structures continually exposed to fluids or retainingfluids. Such intervals have been shown to be adequate todetect degradation of water-control structures before they havea significant effect on plant safety. RG 1.127 also describesspecial inspections immediately following the occurrence ofsignificant natural phenomena, such as large floods,earthquakes, hurricanes, tomadoes, and intense local rainfalls.

Oyster Creek:

a) Visual inspections are used to detect degradations of the OysterCreek water control structures. Oyster Creek has noinstruments that measure the behavior of water controlstructures. (Reference: 125.6 paragraph 4.0)

b) There are no records and readings of instruments to review.Oyster Creek current licensing basis has no requirements forinstruments to detect behavior of the water control structures.

c) Oyster Creek water control structures are monitored periodicallyto detect age related degradations that could impact theirintended function. Accessible structures are monitored on afrequency of 4 years consistent with the frequency forimplementing the requirements of the 10 CFR Part 50.65,

D.Ashley-PBD B.1 .32 Water Control Structures Rev. O.doc Pacje 16 IBD B.1.3 Watr Contro Structures Rev. O.doc Page 160


Maintenance Rule. Inaccessible structures are inspected whenthey become accessible. The intake structure componentssubmerged in water are inspected when the structure isdewatered (Reference: 125.6 paragraph 2.3).

As an enhancement to the existing Oyster Creek RG 1.127,Inspection of Water-Control Structures Associated with NuclearPower Plants program, Oyster Creek committed to inspectsubmerged structures prior to the period of extended operation.Additional inspections will be performed when the structures aredewatered or on a frequency not to exceed 10 years. After eachinspection, the identified degradations will be evaluated todetermine if more frequent inspections are warranted to ensure thatthe intended function of the water control structures is notadversely impacted.

During the NRC aging management program (AMP) review audit,the Staff indicated that the 1 0-year inspection frequency is notconsistent with the 5-year frequency specified in NUREG-1 801Program XI.57, RG 1.127, Inspection of Water-Control StructuresAssociated with Nuclear Power Plants and requested technicalbasis for concluding a 10 year inspection frequency is sufficient forsubmerged portions of water control structures. Oyster Creekindicated that the review of the CLB concluded that the existingOyster Creek RG 1.127, Inspection of Water Control StructuresAssociated With Nuclear Power Plants program is based on SEPTopic 111-3.C commitments, which do not address submergedstructures. The 10-year inspection frequency was determinedsufficient, based on operating experience, to detect significant agerelated degradations before an intended function of the watercontrol structures is adversely impacted. Additionally Oyster Creekwill perform a baseline inspection of underwater structures andevaluate identified age related degradations to establish if there isa need for more frequent inspection to provide reasonableassurance that aging effects are adequately managed. The Staffnoted that the presented existing operating experience related tounderwater structure is not sufficient for the Staff to conclude withreasonable assurance that the 1 0-year inspection frequency isadequate.

As a result of the Staff's concern, Oyster Creek agreed to performa baseline inspection of submerged water control structures prior toentering the period of extended period of operation. A secondinspection will be performed 6 years after the baseline inspection.A third inspection will be performed 8 years after the second

D. As.1.32 Water Control Structures Rev. _.doc


inspection. Following each inspection, the identified degradationswill be evaluated to determine if more frequent inspections arewarranted or there is a need for corrective actions to ensure thatage related degradations are adequately managed. Thisconstitutes a new enhancement not previously identified in theLRA.

d) The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants agingmanagement program is not committed to the inspectionfrequencies specified in ACI 349.3R. The inspection frequencyof Oyster Creek water control structures is discussed in item c)above.

The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants programrequires inspection of water control structures, associated withemergency cooling system, following the occurrence ofsignificant natural phenomena, such as large floods,earthquakes, hurricanes, and tornadoes. There are norequirements to inspect water control structures followingintense local rainfalls because no part of the structures iscredited for flood protection in the CLB (Reference: ABN-31,paragraph 3.6.11(G); ABN-38 paragraph 3.3)


The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants takes exceptionto the inspection frequency specified in NUREG-1 801 XI.S7, RG1.127, Inspection of Water-Control Structures Associated withNuclear Power Plants. This exception is applicable only tosubmerged structures. Technical basis for this exception isexplained above. This is a new exception not previously identifiedin the LRA.


The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants agingmanagement program will be enhanced to require performing abaseline inspection of submerged water control structures prior toentering the extended period of operation. A second inspection willbe performed 6 years after the baseline inspection, with a thirdinspection 8 years after the second. Following each inspection, theidentified degradations will be evaluated to determine if more

[D Ashley-~ -��PB --B.1- -X~ .3 -ae Contro Stutue Rev O1doc Paae 18 II 1 'l- 1~"" ,, I IFP. - PBD B.1.32 Water Control Structures Rev. 0-doc 'Paae'18 1

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frequent inspections are warranted or there is a need for correctiveactions to ensure that age related degradations are adequatelymanaged. This constitutes a new enhancement not previouslyidentified in the LRA


This element is consistent with NUREG-1 801 XI.S7, Inspection ofWater-Control Structures Associated with Nuclear Power Plants,Element 4, Detection of Aging Effects with enhancements and anexception.


NUREG-1 801:

a) Water-control structures are monitored by periodic inspection asdescribed in RG 1.127.

b) In addition to monitoring the aging effects identified in Attribute(3) above, inspections also monitor the adequacy and quality ofmaintenance and operating procedures. RG 1.127 does notdiscuss trending.

Oyster Creek:

a) Water control structures are monitored by periodic inspectionsconsistent with RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants, except asnoted in paragraph 3.4 above.

b) The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants agingmanagement program requires periodic inspection of watercontrol structures for aging related degradations. The existingprogram contains no requirements for monitoring the adequacyand quality of maintenance and operating procedures.According to NRC RG 1.127 this requirement applies to themaintenance and operating procedures that pertain to thesafety of the dam. The inspection of the Fire Pond Dam isconducted in accordance with New Jersey Department ofEnvironmental Protection's Dam Safety Section,"Guidance forInspection of Existing Dams" dated March 2004". Theinspections include monitoring of maintenance and operatingprocedures related to the safety features of the dam(Reference: 4.3.13 Appendix A).


.D. Ashley -PBD B.1.32 WaterControl Structures Rev. O.doc P 19


None.


None.


This element is consistent with NUREG-1 801 XI.S7, RG 1.127,Inspection of Water-Control Structures Associated with NuclearPower Plants, Element 5, Monitoring and Trending.


NUREG-1 801:

a) Acceptance criteria to evaluate the need for corrective actionsare not specified in RG 1.127. However, the "EvaluationCriteria"provided in Chapter 5 of ACI 349.3R-96 provides

b) Acceptance cntena (including quantitative cntena) fordetermining the adequacy of observed aging effects andspecifies criteria for further evaluation. Although not required,plant-specific acceptance criteria based on Chapter 5 of ACI.349.3R-96 are acceptable. Acceptance criteria for earthenstructures such as dams, canals, and embankments are to beconsistent with programs falling within the regulatory jurisdictionof the Federal Energy Regulatory Commission (FERC) or theU.S. Army Corps of Engineers.

Oyster Creek:a) The Oyster Creek RG 1.127, Inspection of Water Control

Structures Associated With Nuclear Power Plants agingmanagement program uses quantitative criteria and qualifiedpersonnel for determining the adequacy of the observed agingeffects. Acceptance criteria and criteria for further evaluationare provided in the program and are consistent with the criteriaoutlined in industry codes and standards including ACI 349.3R-96 (Reference: 125.6 paragraph 4.2 and 7.0)

b) For water structures other than the Fire Pond Dam, observedaging effects are evaluated by qualified personnel withexperience in the design, and inspection of nuclear structuresconsistent with the requirements of 10 CFR Part50.65(Reference: 125.6 paragraph 4.2). The Fire Pond Damis inspected by a professional engineer certified to perform dam

I

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inspection in accordance with the New Jersey Department ofEnvironmental Protection's Dam Safety Section," Guidance forInspection of Existing Dams" dated March 2004"Jersey.Acceptance criteria is based on quantitative evaluation of thedam's condition to ensure public safety consistent with theobjective of FERC and RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants (Reference:4.3.13). These existing Fire Pond Dam inspections will becontinued and administered under the Oyster Creek RG 1.127,Inspection of Water Control Structures Associated With NuclearPower Plants.

Exceptions to NUREG-1 801, Element 6:

None.


None.


This element is consistent with NUREG-1 801 XI.S7, RG 1.127,Inspection of Water-Control Structures Associated with NuclearPower Plants, Element 6, Acceptance Criteria.


NUREG-1 801:

RG 1.127 recommends that the licensee's inservice inspection andsurveillance program include periodic inspections of water-controlstructures to identify deviations in structural conditions due to age-related deterioration and degradation from the original designbasis. When findings indicate that significant changes haveoccurred, the conditions are to be evaluated. This includes atechnical assessment of the causes of distress or abnormalconditions, an evaluation of the behavior or movement of thestructure, and recommendations for remedial or m atingmeasures. As discussed in the appendix to this report, the stafffinds the requirements of 10 CFR Part 50, Appendix Ok acceptableto address the corrective actions.

Oyster Creek:

The Oyster Creek RG 1.127, Inspection of Water ControlStructures Associated With Nuclear Power Plants aging

V11_-1_ -- __ - - �- - - - -_ - - , - - , __ __ -, " - � - - - -, - � -_ -1 - I- I -

F D. Ashlev - PBD B.1.32 Water Control Structures Rev. O.doc Paae 21 XI D. Ashley - PBD B.1 .32 Water Control Structures Rev. O.doc Paae 211


management program requires periodic inspections of water controlstructures to identify deviations in structural conditions due to age-related deterioration and degradation from the original designbasis. Evaluations are performed for inspection results that do notsatisfy established criteria and an Issue Report is initiated todocument the concern in accordance with 10 CFR Part 50,Appendix B, Corrective Action Program. The corrective actionprocess ensures that the conditions adverse to quality are promptlycorrected. If the deficiency is assessed to be significantly adverseto quality, the cause of the condition is determined and an actionplan is developed to preclude repetition.


None.


None.


This element is consistent with NUREG-1 801 XI.S7, RG 1.127,Inspection of Water-Control Structures Associated with NuclearPower Plants, Element 7, Corrective Actions.


NUREG-1 801:As discussed in the appendix to this report, the staff finds therequirements of 10 CFR Part 50, Appendix B, acceptable toaddress the confirmation process.

Oyster Creek:

Site quality assurance (QA) procedures, review and approval.processes, and administrative controls are implemented inaccordance with the requirements of 10 CFR Part 50, Appendi B.


None.


None.

D. Ashley - PBD B.1.32 Water Control Structures Rev. O.doc Page 22



This element is consistent with NUREG-1 801 XI.S7, RG 1.127,Inspection of Water-Control Structures Associated with NuclearPower Plants, Element 8, Confirmation Process.


NUREG-1801:

As discussed in the appendix to this report, the staff finds therequirements of 10 CFR Part 50, Appendix B, acceptable toaddress the administrative controls.

Oyster Creek:

See Item 8, above.


None.


None.


This element is consistent with NUREG-1 801 XI.S7, RG 1.127,Inspection of Water-Control Structures Associated with NuclearPower Plants, Element 9, Administrative Controls.


NUREG-1 801:

Degradation of water-control structures has been detected, throughRG 1.127 programs, at a number of nuclear power plants, and insome cases, it has required remedial action. No loss of intendedfunctions has resulted from these occurrences. Therefore, it can beconcluded that the inspections implemented in accordance with theguidance in RG 1.127 have been successful in detecting significantdegradation before loss of intended function occurs.

NOTE: For dam inspection and maintenance, programs under theregulatory jurisdiction of FERC or the U.S. Army Corps ofEngineers, continued through the period of extended operation, will

YID. Ashley - POD 3.11.32 Water Control S'tru'ctu-re-s Rev. O.doc= = ::-.< ' . ......... 4

Pae 231ID. Ashley - PBD B.1 .32 Water Control Structures Rev. O.doc Paae 23'


be adequate for the purpose of aging management. For programsnot falling under the regulatotyjurisdiction of FERC or theU.S. Army Corps of Engineers, the staff will evaluate theeffectiveness of the aging management program based oncompatibility to the common practices of the FERC and Corpsprograms.

Oyster Creek:

Review of industry operating experience noted that degradationshave occurred in water control structures associated with nuclearpower plants. The degradations were detected though the RG1.127, Inspection of Water Control Structures Associated WithNuclear Power Plants aging management program and correctedbefore a loss of an intended function. The plant specific operatingexperience review also shows that degradations have occurred andhave been identified through the Structures Monitoring agingmanagement program which implements Oyster Creek RG 1 .127,Inspection of Water Control Structures Associated With NuclearPower Plants requirements. The degradations were generallyminor; but some required corrective actions to ensure that theintended function is maintained.

Operating experience, both internal and extemal, is used in twoways at Oyster Creek to enhance plant programs, prevent repeatevents, and prevent events that have occurred at other plants fromoccurring at Oyster Creek. The first way in which operatingexperience is used is through the Oyster Creek OperatingExperience process. The Operating Experience process screens,evaluates, and acts on operating experience documents andinformation to prevent or mitigate the consequences of similarevents. The second way is through the process for managingprograms. This process requires the review of program relatedoperating experience by the program owner.

Both of these processes review operating experience from bothexternal and internal (also referred to as in-house) sources.External operating experience may include such things as INPOdocuments (e.g., SOERs, SERs, SENs, etc.), NRC documents(e.g., GLs, LERs, INs, etc.), General Electric documents (e.g.,RCSILs, SILs, TlLs, etc.), and other documents (e.g., 1 OCFR Part21 Reports, NERs, etc.). Internal operating experience mayinclude such things as event investigations, trending reports, andlessons learned from in-house events as captured in programnotebooks, self-assessments, and in the 10 CFR Part 50, Appendix

. Ashe PBD B.1.32 Water Control Structures Rev. O.doc Pa;e_24


B corrective action process.

Demonstration that the effects of aging are effectively managed isachieved through objective evidence that shows that loss ofmaterial, cracking, and change in material properties for concretecomponents, loss of material and change in material properties forwooden components, and loss of material, and loss of form for thedam, and the canal slopes is being adequately managed in watercontrol structures. The following examples of operating experienceprovide objective evidence that the RG 1 .127, Inspection of Water-Control Structures Associated with Nuclear Power Plants programis effective in assuring that intended function(s) will be maintainedconsistent with the CLB for the period of extended operation:

1. In 1985, GPUN launched an investigation to evaluate thestructural condition of the intake structure (Reference: 4.3.17).Cracking attributed to freeze-thaw and some corrosion of rebarwere observed on the operating deck underside. In thel 986refueling outage, GPUN dewatered the north bay of the intakestructure, cleaned up the marine growth on the concrete surfaceunder the water line and performed additional inspections,including taking core-bores for compressive strength testing.Only a few areas with minor degradations were found under thewater line. Degraded areas were repaired before the north baywas returned to service. The repaired areas were inspectedagain during the 1994 refueling outage. A few areas of re-occurring rebar corrosion were observed and repaired.

Similar degradations were observed on the operating deck ofthe-south bay. The degradations were repaired during the1988, 1989 refueling outage and re-inspected during the 1994refueling outage. The inspection results of the south bay duringthe 1994 refueling outage showed that the structure is in goodcondition. Inspections performed in 2002 noted local spallingand cracking of concrete in addition to some rusted supportmembers. The inspector concluded that the overall condition ofthe Intake structure is structurally sound and acceptable toperform its intended function. The 2002 inspection alsoidentified minor cracks on the lower deck walls of the dilutionstructure. The cracks were determined not to have an adverseimpact on the intended function of the structure.

Inspection of the intake canal, performed in 2001, identifiedsome cracks and fissures, voids, holes, and localized washoutof coatings that protect embankment slopes from erosion. The

aBD B..3 Wae A UCotl Structre Rev O.doc D. Asley-PD B. .32 aterContrl Strcturs Rev 0.dc Pag 251


degradations were evaluated and determined not to impact theintended function of the intake canal (Ultimate Heat Sink). Thedegradations are inspected periodically and evaluated to ensurethat the intended function of the intake canal is not adverselyimpacted.

2. The 1992 "Regular Inspection" of the Fire Pond Dam identifiedtwo areas of the downstream sheeting that were bulgingoutward from the dam. To stabilize the situation, approximately130 cubic yards of riprap was placed in the scour areas andalong the entire downstream length of the spillway. Inspectionsperformed in 2001 found no areas of erosion or structuralinstability. The inspection concluded that repairs made in 1992seemed to have stabilized the spillway and no additionalmovement was noted during the inspection (Reference 4.3.12page 2; 4.3.13 paragraph 3).

The 2004 "Informal Inspection" of the Fire Pond Dam notedsigns of erosion downstream of the right spillway wing wall,which has exposed the lower part of the bulkhead. This couldcompromise the integrity of the spillway wing wall and furthertriggered erosion of the area. However the dam andappurtenant structures are in a safe condition (Reference:4.3.13 paragraph 5)

3. CAP 00360630 was issued in August 2005 as a result of lowlevel in the north structure. The cause of the low water levelwas attributed to debris accumulation on the trash racks. Alsothe trash racks collapsed due to excessive load of the debrisand hydrostatic pressure. Inspection and evaluation of thefailure mechanism of the trash rack concluded that the failure isnot age degradation related. Instead, the failure was due to adesign feature of the trash racks purposely provided to failunder excessive load to avoid catastrophic failure of the intakestructure.

The operating experience of Oyster Creek RG 1.127, Inspection ofWater-Control Structures Associated with Nuclear Power Plantsprogram did not show any adverse trend in performance.Problems identified would not cause significant impact to the safeoperation of the plant, and adequate corrective actions were takento prevent recurrence. There is sufficient confidence that theimplementation of Oyster Creek RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants programwill effectively manage age related degradations associated with

[ D. Ashley - PBD 13.1.32 Water Control Structures ^Rev. 0.doc -I1,- Pia' e- 26 XI D Asley- PD B1 .2 WterCotro StuctresRev O~oc aa 261 -


water control structures consistent with the current licensing basis.Periodic self-assessments of the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants programare performed to identify the areas that need improvement tomaintain the quality performance of the program.

3.10 Conclusion

The Oyster Creek RG 1.127, Inspection of Water-ControlStructures Associated with Nuclear Power Plants agingmanagement program is credited for managing loss of material,cracking, change in material properties, and loss of form for thestructures, components, and environments listed in Table 5.2. TheOyster Creek RG 1.127, Inspection of Water-Control StructuresAssociated with Nuclear Power Plants program's elements havebeen evaluated against NUREG-1 801 in Section 3.0. Programexceptions have been identified in Section 2.3. Programenhancements have been identified in Section 2.4. Theimplementing documents for this aging management program arelisted in Table 5.1. The relevant operating experience has beenreviewed and a demonstration of program effectiveness is providedin Section 3.10. Based on the above, the continuedimplementation of the Oyster Creek RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Structures agingmanagement program provides reasonable assurance thatmanaging loss of material, cracking, and change in materialproperties for concrete components, loss of material and change inmaterial properties for wooden components, and loss of material,and loss of form for the dam, and the canal slopes andembankment will be adequately managed so that the intendedfunctions of components within the scope of license renewal will bemaintained during the period of extended operation

4.0 REFERENCES





D. Ashley- PBD B.1.32 Water Control Structures Rev. O.doc Page 27


4.1.4 NUREG-1801, Generic Aging Lessons Leamed (GALL)Report, Revision 1, dated September 2005


4.2.1 Regulatory Guide 1.127, Inspection of Water-ControlStructures Associated With Nuclear Power Plants, Rev. 1

4.2.2 NEI 96-03, "Industry Guideline for Monitoring the Conditionof Structures at Nuclear Power Plants", Revision D (draft).

4.2.3 ACI 349.3R-96, "Evaluation of Existing Nuclear Safety-Related Concrete Structures".


4.3.1 10 CFR Part 50, Section 65, "Requirements for Monitoringthe Effectiveness of Maintenance at Nuclear Power Plants",Office of the Federal Register, National Archives andRecords Administration, 2000.

4.3.2 NUREG-1 382 Safety Evaluation Report related to the full-term operating license for Oyster Creek Nuclear GeneratingStation, Docket 50-219.

4.3.3 NUREG-0822, Integrated Plant Safety Assessment,Systematic Evaluation Program Oyster Creek NuclearGenerating Station, GPU Nuclear Corporation and JerseyCentral Power & Light Company, Docket 50-219; FinalReport dated January 1983.

4.3.4 NRC Regulatory Guide 1.160, Revision 2, Monitoring theEffectiveness of Maintenance At Nuclear Power Plants U.S.Nuclear Regulatory Commission, March 1997.

4.3.5 NUMARC 93-01, Revision 2, "Industry Guideline forMonitoring the Effectiveness of Maintenance at NuclearPower Plants", Nuclear Management and ResourcesCouncil, Inc.

4.3.6 Procedure 125.6, "Building Structure Monitoring Plan",Revision. 4

4.3.7 TDR 1245, "OC Plant Critical Structures, Life ExtensionAssessment".

. A!� - PBD 13.1.32 Water Control Structures Rev.[0---� ...... � � " - ___010 , 0, -, , , _-_� -- -_'_' -, __- - --, -, ---_o` � _', � _-, __ __- � " � " _�' , " � 0 '_- � , , " -� -6,1�� , ,-- ,=,@: a i f

Ofi6Paqe Zo81HUH: ':S. WIT . . X,2,,;,,,;>wD. Asle -/ PBD( B. _,=1 WW_== .3W te Co trol_ Structrs Rev. 0 _.doc . PAcac .. 1ie. ==.FEE 28= I . ETX. W St_ _ _,,. dm;A _ _ _ __a.a.i:.:ig x


4.3.8 Procedure ABN-32, "Abnormal Intake Level".

4.3.9 Procedures ABN-31, "High Winds"

4.3.10 Procedure ABN-38, "Station Seismic Evenf'

4.3.11 "Intake Structure Inspection Report, Run Cycle 16 Nov.1996"

4.3.12 Report No. 176-1, Regular Dam Inspection Report,Freshwater Impounding Pond Dam Oyster Creek GeneratingStation dated November 2001.

4.3.13 2004 Informal Inspection of Fresh Water Impounding ofFresh Water Impounding Pond Dam at Oyster CreekGenerating Station File No. 33-24, dated January 2005.

4.3.14 Final Report on Evaluation of the Bulkhead Repairs at theOyster Creek Nuclear Generating Station, dated April 1988.

4.3.15 CAP No. 02001-0747, 'The Trash rack rail at the intakestructure is severely corroded"

4.3.16 Calculation C-1 302-168-5320-006, "Intake StructureOperating Slab Concrete Repair'

4.3.17 Specification OCIS 402558-003, "Below Water LineConcrete Surface Inspection & Testing at Intake Structure"

4.3.18 NRC letter dated June 24,1982, Oyster Creek, Evaluation ofSEP Topic 111-3.C, Inservice Inspection of Water ControlStructures.

4.3.19 Procedure ABN-32, Abnormal Intake Level

4.3.20 GPU letter to NRC dated November 1,1981, Transmittal ofSafety assessment Reports for SEP Topics

4.3.21 NRC letter data January 22,1982, SEP Topic Il-3.C,Request for Additional Information

4.3.22 NRC AMP Information Requests, AMP-073, AMP-074, AMP-075, AMP-076, AMP-077, and AMP-078.

D.Ashley - PBD B1.3 Water Control Sructures Rev. O.docLI( . -,, * _ : ,, .. . St , I, = = ,. .I ; I m e , ~ , ~ ~ .. , - I.. .

, Page6 29d:::...._.;.=S.=a==..._S..:N:EW=3;:===.521_/dl;D;l=M'__i_14(u:::X:_:1

D. Ashley-PBD B.1.32 Water Control Structures Rev. O.doc Paae 29�

Oyster Creek PBD-AMP-B.1.32, Revision 0License Renewal Project Page 29-of 35RG 1.127, Inspection of Water-Control Structures Associated with NuclearPower Plants

5.0 TABLES

5.1 Aging Management Program Implementing Documents

Procedure Number Procedure Title Commitment StatusNo.-

125.6 Building Structure 330592.32.01 ACC/ASGMonitoring Plan

-ABN-31 High Winds 330592.32.02 ACC/ASGABN-32 Abnormal Intake Level 330592.32.03 ACC/ASGABN-38 Station Seismic Event 330592.32.04 ACC/ASG

- - I", -11 I - , ... -1- - , � � �- ,, I 11 11 11 I I I � -F D. Ashlev - PBD B.1.32 Water Control Structures Rev. O.doc Pane 30B- - - - - - - - - - - - - - - - --- -- - � � - =�� - - X� -- �� K, H-� �� - -

Oyster Creek'Ucense Renewal ProjectInspection of Water-Control Structures Associated with Nuclear Power Plants



ilution Structure einforced concrete foundation oncrete ater - flowing oss of Materialilution Structure einforced concrete foundation ,oncrete oil rackingilution Structure einforced concrete Walls oncrete utdoor Air hange in Material

Propertiesilution Structure einforced concrete Walls oncrete utdoor Air racking

Dilution Structure Reinforced concrete Walls oncrete utdoor Air oss of MaterialDilution Structure Reinforced concrete foundation oncrete il *rackin2Dilution Structure Reinforced concrete Walls oncrete ressive change in Material

_nvironrnent 2ropertiesDilution Structure einforced concrete Wails oncrete ggressive C racking

_nvironmentDilution Structure einforced concrete Walls oncrete gressive ass of Material

_nvironmentDilution Structure einforced concrete foundation oncrete gressive ass of Material

_nvironmentDilution Structure Reinforced concrete foundation Concrete gressive hange in Material

. Environment ropertiesilution Structure einforced concrete foundation oncrete ater - flowing hange in Material

_roperfies

ilution Structure R inforced concrete foundation oncrete gressive 3racking_ nvironrment

ilution Structure Reinforced concrete Walls o crete ressive racking. Environmnent

Dilution Structure einforced concrete Walls oncrete utdoor Air ass of MaterialDilution Structure cinforced concrete Walls *oncrete r Air Crackingilution Structure Reinforced concrete Walls oncrete l .racking

Dilution Structure cinforced concrete Walls oncrete ater - flowing ihange n Material_roperties

Oilution Structure Reinforced concrete Walls oncrete ater - flowing ass of MaterialDfilution S cnied concrete alls Qncrwe rkir a King

1 b. Ashley - PBD B.1 .32 Water Control Structures Rev. O.doc Paui�'3`1A-, , -- .�-., __Ile- X--- ---- -- � - � - --

Oyster CreekLicense Renewal Projectinspection of Water-Control Structures Associated with Nuclear Power Plants



ilution Structure Reinforced concrete foundation oncrete gressive racking_nvironment

Fire Pond Dam Fire Pond Dam arious (concrete, wood, soil, ater - flowing, Water Loss of material,_ock, grout, galvanized steel) tanding Loss of form

ntake Structure and Canal Reinforced concrete foundation oncrete door Air L oss of Material'Ultimate Heat Sink)ntake Structure and Canal einforced concrete foundation rete gressive C racking(Ultimate Heat Sink) Environment

Intake Structure and Canal Reinforced concrete foundation oncrete ssive Change in Material(Ultimate Heat Sink) Environment Propertiesntake Stnrcture and Canal Reinforced concrete foundation oncrete gressive 3racking(Ultimate Heat Sink) . Environmentntake Structure and Canal Reinforced concrete foundation uoncrete door Air s of Material(Ultimate Heat Sink)ntake Structure and Canal Reinforced concrete foundation oncrete utdoor Air racking(Ultimate Heat Sink)ntake Stnrcture and Canal Reinforced concrete foundation crete utdoor Air Change in MaterialUltimate Heat Sink) . Propertiesntake Structure and Canal Reinforced concrete Slab Concrete Dutdoor Air Loss of Material:Ultimate Heat Sink)ntake Stnrcture and Canal leinforced concrete Slab oncrete utdoor Air C racking'Ultimate Heat Sink)ntake Structure and Canal Earthen water control structures arious (Gravel, Tar, Soil, wood, ater (flowing, -oss of FormUltimate Heat Sink) intake canal, embankments) alvanized steel) tanding)ntake Structure and Canal Earthen water control structures arious (Gravel, Tar, Soil, wood, ater (flowing, oss of Material'Ultimate Heat Sink) intake canal, embankments) ized steel) rnding)ntake Structure and Canal Reinforced concrete foundation oncrete utdoor Air rackingUltimate Heat Sink) '' . . . . . .... _ __ .. . .ntake Stnrcture and Canal Reinforced concrete foundation concrete ater - Flowing hange in MaterialUltimate Heat Sink) __ Propertiesntake Structure and Canal reinforced concrete Slab Concrete .. utdoor Air hange in MaterialUltimte Het nk)reries

E D. Ashley -- PBD-B'.1'.'32 Water Control Structures Rev. O.doc Paae 32 ADP3ncO 32- - - -'I

Oyster CreekLicense Renewal ProjectInspection of Water-Control Structures Associated with Nuclear Power Plants



ntake Structure and Canal Reinforced concrete Walls Concrete ggressive hange in Material[Ultimate Heat Sink) Environment ropertiesntake Structure and Canal Reinforced concrete Walls Concrete utdoor Air hange in Material'Ultimate Heat Sink) droperties

ntake Structure and Canal Reinforced concrete Walls Concrete utdoor Air rackingUltimate Heat Sink)ntake Structure and Canal einforced concrete Walls Concrete utdoor Air rackingUltimate Heat Sink)ntake Structure and Canal 3einforced concrete Walls Concrete Dutdoor Air CrackingUltimate Heat Sink)ntake Structure and Canal Reinforced concrete Walls Concrete Dutdoor Air Loss of MaterialUltimate Heat Sink)ntake Structure and Canal einforced concrete Walls C oncrete Outdoor Air L oss of MaterialUltimate Heat Sink)ntake Structure and Canal Reinforced concrete Slab Concrete oil CrackingUltimate Heat Sink)ntake Structure and Canal einforced concrete Walls Concrete oil C rackingUltimate Heat Sink)ntake Structure and Canal einforced concrete Slab oncrete utdoor Air C racking'Ultimate Heat Sink)ntake Structure and Canal einforced concrete Walls oncrete ater -Flowing s of MaterialUltimate Heat Sink)ntake Structure and Canal einforced concrete foundation crete door Air rackingUltimate Heat Sink)ntake Structure and Canal Reinforced concrete Walls oncrete gressie rackingUltimate Heat Sink) onviinmentItake Structure and Canal einforced concrete Walls oncretegressive racking

(Ultimate Heat Sink) . nvironmentntake Structure and Canal Reinforced concrete Walls Concrete gressive Loss of MaterialUltimate Heat Sink) Inyironment .ntake Structure and Canal Reinforced concrete foundation oncrete ater -Flowing ass of MaterialUltimat Heat sin l_!-_

DAhley - PBD B.1 32 Water Control Structures Rev. O.doc Page 3~----- -

Oyster CreekLicense Renewal ProjectInspection of Water-Control Structures Associated with Nuclear Power Plants



ntake Structure and Canal Reinforced concrete foundation Concrete Aggressive Loss of MaterialUltimate Heat Sink) Ernvironmentntake Structure and Canal einforced concrete Slab Concrete Outdoor Air CrackingUltimate Heat Sink)ntake Structure and Canal einforced concrete Slab Concrete Outdoor Air Loss of MaterialUltimate Heat Sink) Intake Structure and Canal einforced concrete foundation Concrete Soil rackingUltimate Heat Sink)ntake Structure and Canal cinforced concrete foundation Concrete Soil rackingUltimate Heat Sink)ntake Structure and Canal einforced concrete Walls Concrete Water - Flowing ihange n MaterialUltimate Heat Sink) Properties

BD B.1.32 Water Control Structures Rev. O.doc Pa,,,,

Oyster Creek PBD-AMP-B.1.32, Revision 0License Renewal Project Page 34 of 35Inspection of Water-Control Structures Associated with Nuclear PowerPlants

6.0 ATTACHMENTS

6.1 LRA Appendix A

6.2 LRA Appendix B

k D. Asileyv- OB'D B. 1'.2'6" Burie~d piping'Re'v 0 doe Page I II D. Ashtev - PBD B.1 .26 Buried DiDiflO Rev O.doc Paae 1 1

Oyster Creek PBD-AMP.License Renewal ProjectBuried Piping Inspection


-B.1.26, Revision 0Page 1 of 21

PBD-AMP-B.1 .26

Revision 0

- BURIED PIPING INSPECTION

GALL PROGRAM XI.M34 - BURIED PIPING AND TANKS INSPECTION

Prepared By:

Reviewed By:



Revision History:Revision Prepared by: Reviewed by: Program Approved by:

._ Owner:0 S. Rafferty- C. Micklo Pete Tamburro Fred Polaski

CzincilaDate

[0. Ashey - PD B1 26"Buri edpipsin Rev O.doc Page 2 1-- - -- X- I--- -- � I--- -- -=�-- -- .--- -- �- -----I - --1 -- - -- X--------.-

Oyster CreekLicense Renewal ProjectBuried Piping Inspection




I,,A

[ = -A"'s-'-hle -P-BD B'.1.2w6 B'uried pipina ARev O.doc P ag---e 3- |11I D. Ashley PBD B.1 .26 Buried DiDiflO Rev 0.doc Pacie 31

Oyster Creek PBD-AMP-B.1.26, Revision 0License Renewal Project Page 3 of 21Buried Piping Inspection

TABLE OF CONTENTS



3.0 EVALUATIONS AND TECHNICAL BASIS 93.1 Scope of Program 123.2 Preventive Actions 133.3 Parameters Monitored or Inspected 133.4 Detection of Aging Effects 153.5 Monitoring and Trending 173.6 Acceptance Criteria 183.7 Corrective Actions 193.8 Confirmation Process 203.9 Administrative Controls 203.10 Operating Experience 213.11 Conclusion 24

4.0 REFERENCES 254.1 Generic to Aging Management Programs 254.2 Industry Standards 254.3 Oyster Creek Program References 25

5.0 Tables 255.1 Aging Management Prograrn Implementing Documents 255.2 Aging Management Review Results 28

6.0 Attachments 306.1 LRA Appendix A6.2 LRA Appendix B

I D.Ashley- PBD B.1.26 Buried piping Rev 0.doc Paae 41

hle - .. 2 Bu !in g Reva O doc Pjag-e'41



1.1 Purpose

The purpose of this Program Basis Document is to document andevaluate those activities of the Oyster Creek Buried PipingInspection aging management program that are credited formanaging loss of material due to the effects of corrosion on thepressure-retaining capacity'of piping and components in a soil(external) environment as part of Oyster Creek License Renewal tomeet the requirements of the License Renewal Rule 10 CFR 54,"Requirements for Renewal of Operating Licenses for NuclearPower Plants."




• The review of Operating Experience to demonstrateprogram effectiveness;

* The identification of required program enhancements;and

* The identification of Oyster Creek documents requiredto implement the program

1.2 Methodology

The nuclear power plant License Renewal Rule 10 CFR 54,"Requirements for Renewal of Operating Licenses for Nuclear PowerPlants," describes the License Renewal process and providesrequirements for the contents of License Renewal Applications. 10 CFR54.21 (a)(3) states:

'For each structure and component identified in paragraph (a)(1) of thissection, demonstrate that the effects of aging will be adequately managedso that the intended function(s) will be maintained consistent with theCurrent Licensing Basis (CLB) for the period of extended operation."

The NRC and the industry identified 10 program elements that are usefulin describing an aging management program and then demonstrating itseffectiveness. These program elements are described in Appendix A.1,Section A.1.2.3 of the Standard Review Plan. NUREG-1801 uses theseprogram elements in Section Xl to describe acceptable aging

E D. Ashley - PBD B.1.26 Buried piping Rev 0.doc Pagie 5 XD. Ashley - PBD B.1 .26 Buried oloina Rev O.doc Paae 51


management programs.

This Program Basis Document also provides a comparison of the creditedOyster Creek program with the elements of the corresponding NUREG-1801 Chapter Xl program Xl. M34 - Buried Piping and Tanks Inspection.Project Level Instruction PLI-8 "Program Basis Documents" prescribes themethodology for evaluating Aging Management Programs. An evaluationof Oyster Creek's aging management program criteria or activities tothose of the NUREG-1 801 program elements is performed and aconclusion is reached concerning consistency for each individual programelement. A demonstration of overall program effectiveness is made afterall program elements are evaluated. Required program enhancements aredocumented. An overall determination is made as to consistency with theprogram description in NUREG-1801.



NUREG-1 801:

a) The program includes preventive measures to mitigatecorrosion.

b) Periodic inspection to manage the effects of corrosion on thepressure-retaining capacity of buried steel piping and tanks.

c) Gray cast iron, which is included under the definition of steel, isalso subject to a loss of material due to selective leaching,which is an aging effect managed under Chapter Xi.M33,"Selective Leaching of Materials."

d) Preventive measures are in accordance with standard industrypractice for maintaining extemal coatings and wrappings.

e) Buried piping and tanks are inspected when they are excavatedduring maintenance and when a pipe is dug up and inspectedfor any reason.

f) This program is an acceptable option to manage buried pipingand tanks, except further evaluation is required for the programelement/attributes of detection of aging effects (regardinginspection frequency) and operating experience.

Oyster Creek:

a) The program includes preventive measures such as coating andwrapping to prevent loss of material caused by corrosion of theexternal surface of buried piping. Preventive measures are in

[D.Ashley -_PBD BA .26 Buried piping Rev O.doc Page 6Page 6 11


accordance with standard industry practice for maintainingexternal coatings and wrappings. (Reference: ER-AA-330-008,SP-9000-06-003 and SP-9000-06-004)

b) The program includes measures such as periodic inspection tomanage the effects of corrosion on the pressure-retainingcapacity of buried piping. (Reference: TR-1 16 and SA-AA-1 17,Step 4.7)

c) Gray cast iron, which is included under the definition of steel, isalso subject to a loss of material due to selective leaching,which is an aging effect managed under B.1.25 "SelectiveLeaching of Materials" aging management program. Preventivemeasures are in accordance with standard industry practice formaintaining external coatings and wrappings. (Reference: PBD-AMP-B.1.25)

d) The program includes preventive measures such as coating andwrapping to prevent loss of material caused by corrosion of theexternal surface of buried piping. Preventive measures are inaccordance with standard industry practice for maintainingexternal coatings and wrappings. (Reference: ER-AA-330-008,SP-9000-06-003 and SP-9000-06-004)

e) Periodic inspections are performed to manage the effects ofcorrosion on the pressure-retaining capacity of buried piping.Buried piping is inspected when it is excavated duringmaintenance and when a pipe is dug up and inspected for anyreason. (Reference: SA-AA-1 17, Step 4.7)

f) Based on Oyster Creek operating experience, there has beenonly one underground leak that developed as a result of failureof the external coating of carbon steel pipe. In 1992 the ServiceWater system developed a leak that resulted from failure of theexternal coating. The root cause evaluation determined thatfailure was due to improper original coating application.Additionally, in 1980, 1992 & 1996 leaks developed in buriedaluminum Condensate Transfer pipe. As a result 90% of the ALpiping was replaced and relocated aboveground. Subsequently,Oyster Creek initiated the Oyster Creek Underground PipingProgram in which the inspection and modifications of theremaining 25 feet of buried AL Condensate Transfer systempipe are tracked. (Reference: TR-116) To date, there havebeen no other buried pipe leaks due to external degradation.Although failure of buried piping has occurred, it has beendetermined that the loss of integrity of the buried piping leakswere caused primarily from the inside of the buried piping,which is evaluated with the Open Cycle Closed Cooling Water

[ D. AifiiiW- 06b �' ' 1.'2`6" 'Buried piping Rev O.doc �� 'APage i II D. Ashley - PBD B.1 .26 Buried piping Rev O.doc Page 7 I


aging management program. (Reference: PBD-AMP-B.1.13)Therefore the frequency of inspection, at least once in the 10years prior to the period of extended operation and at leastonce in the first 10 years of extended operation, is adequate.Additionally, there have been several yard excavation activitiesto date that have uncovered buried piping and inspections ofthe buried piping have been performed. The results of theseinspections have shown no significant external coating failures.Coatings have been repaired during these inspections inaccordance with corporate procedures. In addition otherinspections and testing have been performed and aredocumented in Technical Data Report "Pipe Integrity InspectionProgram", Topical Report "Emergency Service Water andService Water Piping Plan" and Topical Report "Oyster CreekUnderground Piping Program Description and Status" report.(Reference: TDR-829, TR-1 40 and TR-1 16) All inspection dataand analysis are documented in the above referenceddocuments.

Oyster Creek does not have any buried tanks as defined byNUREG-1 801, Section XI.M.34 Buried Piping and TanksInspection AMP. Therefore the Oyster Creek AMP only consists ofburied piping. Additionally, NUREG-1 801, Section X1.M.34 BuriedPiping and Tanks Inspection AMP only includes buried carbon steelpiping; however, Oyster creek has other pipe material in its buriedpiping program that will bemanaged as part of this AMP.


The Oyster Creek Buried Piping Inspection program is an existingprogram that is consistent with NUREG-1 801 aging managementprogram XI.M34 with exceptions and enhancements as describedin 2.3 and 2.4 below.

2.3 Summary of Exceptions to NUREG-1 801NUREG-1 801, Section Xl.M.34 Buried Piping and TanksInspection AMP only includes buried carbon steel piping;however, Oyster Creek has other material, such as stainlesssteel, aluminum, bronze and cast iron, in their buried pipingprogram that will be managed as part of this AMP. NUREG-1801, Section Xl.M.34 Buried Piping and Tanks InspectionAMP relies on preventive measures such as coatings andwrappings; however, portions of buried stainless steel andbronze piping may not be coated or wrapped. Inspections ofburied piping that is not wrapped will inspect for loss of

I -~s --- B.2 Buried pin ev O.doc gPae8


material due to general pitting, crevice, and microbiologicallyinfluenced corrosion.

* Oyster Creek does not have any buried tanks in the scope oflicense renewal.


The Buried Piping Inspection aging management program will beenhanced to include:

* Fire protection components in the scope of the program.

* Inspection of buried piping within ten years of entering theperiod of extended operation, unless an opportunisticinspection occurs within this ten-year period.

* Piping located inside the vault in the scope of the program.The vault is considered a manhole that is located betweenthe reactor building and the exhaust tunnel.


Note

This section is organized by quoting the relevant NUREG-1 801 ChapterXi program element (September 2005 version) followed by the relatedOyster Creek program attributes and a conclusion of the comparison.Where applicable, the NUREG-1 801 program element was separatedinto logical sub-elements and addressed accordingly.



NUREG-1 801:

a) The program relies on preventive measures such as coating,wrapping and periodic inspection for loss of material caused bycorrosion of the extemal surface of buried steel piping andtanks. Loss of material in these components, which may beexposed to aggressive soil environment, is caused by general,pitting, and crevice corrosion, and microbiologically-influencedcorrosion (MIC).

b) Periodic inspections are performed when the components are

ND.Ashley- PBD B.1.26 Burieing Rev Ok doc Pagx9


excavated for maintenance or for any other reason. The scopeof the program covers buried components that are within thescope of license renewal for the plant.

Oyster Creek:

a) The Buried Piping Inspection aging management program is anexisting program that provides for managing loss of materialdue to general corrosion, pitting, crevice corrosion andmicrobiologically-influenced corrosion (MIC) of ferrous materialsthrough the use of piping and component coatings andwrappings, periodic inspections, and pressure testing. Theprogram relies on preventive measures such as coating andwrapping and periodic inspection for loss of material caused bycorrosion of the external surface of buried steel piping.Preventive measures are in accordance with standard industrypractice for maintaining external coatings and wrappings.(Reference: ER-AA-330-008, SA-AA-1 17, SP-9000-06-003and SP-9000-06-004)

b) Periodic inspections are performed when the components areexcavated for maintenance or for any other reason. Thecorporate procedure, "Excavation, Trenching, and Shoring"directs engineering to perform inspections of piping exposedduring excavation for coating degradation or corrosion.(Reference: SA-AA-1 17, Step 4.7) The Oyster Creek buriedpiping activities consist of inspections, preventive and condition-monitoring measures to manage the loss of material due tocorrosion from external environments for buried ferrous pipingin the scope of license renewal. Additionally, Oyster Creekutilizes corporate procedures to control application maintenanceand periodic assessment of safety related and non-safetyrelated coatings. (Reference: ER-AA-330-008)

System components within the scope of License Renewalinclude buried portions of the Emergency Service Water,Service Water, Roof Drains & Overboard Discharge, DrywellFloor and Equipment Drains, RBCCW, Fire Protection,Condensate Transfer, Containment Spray, Reactor BuildingFloor and Equipment Drain, Spent Fuel Pool Cooling, WaterTreatment & Distr., Heating and Process Steam, andMiscellaneous Floor & Equipment Drain systems.

The Containment Spray, Drywell Floor & Equipment Drain andMiscellaneous Floor & Equipment Drains have pipe that runsthrough a vault located between the reactor building and thetunnel. The Containment Spray piping has a safety related LR

- -1 I � � I X, I I 11 11 I I I I 1, I 11

L D. Ashlev - PBD B.1.26 Buried Dipina Rev O.doc Pacle 101I D Asley- PD B1 .6 Brie piinaRevO~dc Pc---0


function and therefore the other piping located in the vault withthe Containment Spray piping are in the scope of LR for spatialinteraction. The environment of this vault has beenconservatively considered buried.

The Roof Drains & Overboard Discharge, RBCCW, CondensateTransfer, Reactor Building Floor and Equipment Drain, SpentFuel Pool Cooling, and Miscellaneous Floor & Equipment Drainsystems have buried piping that runs from the tunnel into thereactor building.

ESW, SW, Condensate Transfer and Fire Protection havevarious locations for buried components outside plant buildings.

This program only inspects the external surfaces of buriedcomponents. The aging management of the internalenvironment of buried components will be handled by theprograms associated with the water inside the buriedcomponents including B.1.02 'Water Chemistry", B.1.13 "Open-Cycle Cooling Water System Program", B.1.14 "Closed-CycleCooling Water System Program, and B.1.20 "Fire WaterSystem Program."

The Oyster Creek Buried Piping Inspection aging managementprogram manages the aging effect of loss of material due to theeffects of corrosion on the pressure-retaining capacity of pipingand components in a soil (external) environment for thesystems, components, and environments listed in Table 5.2.The implementing documents for this aging managementprogram are listed in Table 5.1 and are described throughoutthe individual program element discussions. The commitmentnumbers under which these implementing documents are beingrevised are contained within the listings in Table 5.1.


NUREG-1 801, Section X1.M.34 Buried Piping and TanksInspection AMP only includes buried carbon steel piping,however Oyster Creek has other material, such as stainlesssteel, aluminum, bronze and cast iron, in their buried pipingprogram that will be managed as part of this AMP. NUREG-1801, Section Xl.M.34 Buried Piping and Tanks InspectionAMP relies on preventive measures such as coatings andwrappings, however portions of buried stainless steel andbronze piping may not be coated or wrapped. Inspections ofburied piping that is not wrapped will inspect for loss ofmaterial due to general pitting, crevice, and microbiologicallyinfluenced corrosion.

132eP1)DB.1.26 Bue poc age 11


Oyster Creek does not have any buried tanks in the scope oflicense renewal.





* Piping located inside the vault in the scope of the program.


This element is consistent with NUREG-1 801, Element 1, S6ope ofProgram, with exceptions and enhancements as described above.


NUREG-1 801:

In accordance with industry practice, underground piping and tanksare coated during installation with a protective coating system,such as coal tar enamel with a fiberglass wrap and a kraft paperouter wrap, a polyolifin tape coating, or a fusion bonded epoxycoating to protect the piping from contacting the aggressive soilenvironment.

Oyster Creek:The Buried Piping Inspection program relies on preventivemeasures such as coating and wrapping to protect the piping fromcoming in contact with the soil environment. Preventive measuresare in accordance with standard industry practice for maintainingexternal coatings and wrappings. (Reference: ER-AA-330-008, SP-9000-06-003 and SP-9000-06-004)


NUREG-1 801, Section X1.M.34 Buried Piping and TanksInspection AMP only includes buried carbon steel piping, howeverOyster Creek has other material, such as stainless steel,aluminum, bronze and cast iron, in their buried piping program thatwill be managed as part of this AMP. NUREG-1 801, SectionX1.M.34 Buried Piping and Tanks Inspection AMP relies on

D.Ash BD B.1.26 Bu-epn Rev O.doc A AI



preventive measures such as coatings and wrappings, howeverportions of buried stainless steel and bronze piping may not becoated or wrapped. Inspections of buried piping that is not wrappedwill inspect for loss of material due to general pitting, crevice, andmicrobiologically influenced corrosion.


None.


This element is consistent with NUREG-1 801, Element 2,Preventive Actions, with exceptions as described above.


NUREG-1 801:

a) The program monitors parameters such as coating andwrapping integrity that are directly related to corrosion damageof the external surface of buried steel piping and tanks.Coatings and wrappings are inspected by visual techniques.

b) Any evidence of damaged wrapping or coating defects, such ascoating perforation, holidays, or other damage, is an indicator ofpossible corrosion damage to the external surface of piping andtanks.

Oyster Creek:

a) External surfaces are inspected by visual techniques wheneverburied components are uncovered during station excavationactivities per the Exelon Corporate Procedure, "Excavation,Trenching, and Shoring". (Reference: SA-AA-117, Step 4.7)Inspection of buried components identifies coating degradation,if coated, or base metal corrosion, if uncoated. Additionally,preventive maintenance activities open and sample the waterinside the vault next to the Reactor Building every 182 days.The vault is considered a manhole that is located between thereactor building and the exhaust tunnel. (Reference:PM1 0201 M) This preventive maintenance activity will beenhanced to include inspection of the piping located inside thevault.

b) Any evidence of damaged wrapping or coating defects is anindicator of possible corrosion damage to the external surface.Inspections of buried piping that is not wrapped will inspect for

''Ashev - P'B'DB. 1.26 Buried Dipipna Rev O.doc Ipa~~i'ge' II D. Ashley - PBD .1 .26 Buried DiKin Re .o P 3


loss of material due to general pitting, crevice, andmicrobiologically influenced corrosion. Degraded coatings arerepaired per the Oyster Creek procedures and specifications.(Reference: ER-AA-330-008, SA-AA-1 17 and SP-9000-06-04)

Exceptions to NUREG-1 801, Element 3:

None.







This element is consistent with NUREG-1 801, Element 3,Parameters Monitored or Inspected, with enhancements asdescribed above.


NUREG-1 801:a) Inspections performed to confirm that coating and wrapping are

intact are an effective method to ensure that corrosion ofexternal surfaces has not occurred and the intended function ismaintained.

b) Buried piping and tanks are opportunistically inspectedwhenever they are excavated during maintenance. Whenopportunistic, the inspections are performed in areas with thehighest likelihood of corrosion problems, and in areas with ahistory of corrosion problems, within the areas made accessibleto support the maintenance activity.

c) The applicant's program is to be evaluated for the extendedperiod of operation. It is anticipated that one or moreopportunistic inspections may occur within a ten-year period.Prior to entering the period of extended operation, the applicant

Dt.Asley-PiBD B.1.26 Buri f pipngRev O.doc Page 141


is to verify that there is at least one opportunistic or focusedinspection is performed within the past ten years.

d) Upon entering the period of extended operation, the applicant isto perform a focused inspection within ten years, unless anopportunistic inspection occurred within this ten-year period.

e) Any credited inspection should be performed in areas with thehighest likelihood of corrosion problems, and in areas with ahistory of corrosion problems.

Oyster Creek:

a) Inspections will be performed to confirm that coating andwrapping are intact. These inspections are an effective methodto ensure that corrosion of external surfaces has not occurredand the intended function is maintained. Inspections areperformed to confirm that coating and wrapping are intact.External inspections of buried components will occuropportunistically when they are excavated during maintenance.(Reference: SA-AA-1 17, Step 4.7)

b) Buried piping will be opportunistically inspected wheneverexcavated for maintenance. The inspections will be performedon all of the areas made accessible to support the maintenanceactivity. (Reference: SA-AA-1 17, Step 4.7) Areas with thehighest likelihood of corrosion problems, and areas with ahistory of corrosion problems have been identified in TopicalReport "Oyster Creek Underground Piping Program Descriptionand Status". (Reference: TR-1 16)

c) There have been several yard excavation activities to date thathave uncovered buried piping and inspections of the buriedpiping. Oyster Creek has performed focused inspection on theirunderground piping within the past ten years. (Reference: TR-116) Several inspections have been performed on the ESWand SW systems, which have a high likelihood of corrosionproblems and have a history of corrosion related problems. Inaddition other inspections and testing have been performed perthe Technical Data Report "Pipe Integrity Inspection Program"and Topical Report "Oyster Creek Underground Piping ProgramDescription and Status". (Reference: TDR-829 and TR-1 16)

d) Upon entering the period of extended operation inspection ofburied piping will be performed within ten years, unless-anopportunistic inspection occurs within this ten-year period.

e) Areas with the highest likelihood of corrosion problems, andareas with a history of corrosion problems have been identified

D. Ashley - PBD B.1.26 Buried piping Rev O.doc Page 15


in Topical Report "Oyster Creek Underground Piping ProgramDescription and Status". (Reference: TR-1 16) These areprimarily in the ESW and SW systems. Inspections in theseareas have been performed within the past ten years.(Reference: TR-116)

Additionally, Inservice Service Testing and monitoring for the ESW,SW, RBCCW, Fire Protection and Condensate Transfer systemsare performed. (Reference: 641.4.001, 644.4.002, 607.4.014,607.4.015, 645.6.023 and 642.4.001) Monitoring and trendingfrom the performance of these tests can aid in the detection ofsystem pipe leaks. Periodic leak testing and componentinspections are being credited as well. Section Xl Pressure Testingdirects testing of buried cooling water piping for the detection ofleaks. (Reference: ER-AA-330-001 and 2400-SMM-3900.04) Thispressure testing is performed via pump surveillances.


None.







This element is consistent with NUREG-1 801, Element 4, Detectionof Aging Effects, with enhancements as described above.


NUREG-1 801:

Results of previous inspections are used to identify susceptiblelocations.

Oyster Creek:

There have been several yard excavation activities to date thathave uncovered buried piping; inspections of the buried piping

D.AshIey: PBD B.1 .26 Buried piping Rev 0.doc Page 16gee Alaair p.,,q1 Paae 16


have been performed. In addition other inspections and testinghave been performed per Technical Data Report "Pipe IntegrityInspection Program" and Topical Report 'Oyster CreekUnderground Piping Program Description and Status".(Reference: TDR-829 and TR-116) These inspection and testresults are documented as part of the program or proceduralprocesses and sent to the appropriate station personnel fortrending and analysis. Results of previous inspections are used toidentify susceptible locations. (Reference: TR-1 16)


None.


None.


This element is consistent with NUREG-1 801, Element 5,Monitoring and Trending.


NUREG-1 801:

Any coating and wrapping degradations are reported andevaluated according to site corrective actions procedures.

Oyster Creek:

Any coating and wrapping degradations are reported and evaluatedaccording to site corrective actions procedures. Externalcomponent degradation is reported and evaluated whenever buriedcommodities are uncovered during yard excavation activities. Inaddition, evidence of metal surface corrosion and any leakagedetected through periodic testing and visual inspections will beevaluated and used to confirm the system and components abilityto perform their intended functions. Any leakage identified isevaluated and appropriate corrective actions are implemented.(Reference: SA-AA-1 17, Step 4.7, 2400-SMM-3900.04 and ER-AA-330-008)


NUREG-1 801, Section X1.M.34 Buried Piping and Tanks

- - - - - - ---- , - --- 11 - 11 11 � rl

E D. Ashlev - PBD B.1.26 Buried DiDina Rev O.doc ^Paae 17 S0. Ashley - PBD B.1 .26 Buried DiDiflO Rev 0.doc Paae 17


Inspection AMP only includes buried carbon steel piping, howeverOyster Creek has other material, such as stainless steel,aluminum, bronze and cast iron, in their buried piping program thatwill be managed as part of this AMP. NUREG-1 801, SectionX1.M.34 Buried Piping and Tanks Inspection AMP relies onpreventive measures such as coatings and wrappings, howeverportions of buried stainless steel and bronze piping may not becoated or wrapped. Inspections of buried piping that is not wrappedwill inspect for loss of material due to general pitting, crevice, andmicrobiologically influenced corrosion.





• Piping located inside the vault in the scope of the program.


This element is consistent with NUREG-1 801, Element 6,Acceptance Criteria, with exceptions and enhancements asdescribed above.


NUREG-1 801:The site corrective actions program, quality assurance (QA)procedures, site review and approval process, and administrativecontrols are implemented in accordance with the requirements of10 CFR Part 50, Appendix B. The staff finds the requirements of10 CFR Part 50, Appendix B, acceptable to address the correctiveactions, confirmation process, and administrative controls.

Oyster Creek:

Evaluations are performed for test or inspection results that do notsatisfy established criteria and a condition report is initiated todocument the concern in accordance with plant administrativeprocedures that meet the requirements of 10 CFR Part 50,Appendix B. The corrective action program and specific correctiveaction steps as specified in the various annotated procedures

D.AshleyPBD B.1.26 Buriedping Rev .doc __Pae 18



ensure that any conditions adverse to quality are promptlycorrected. If the deficiency is assessed to be significantly adverseto quality, the cause of the condition is determined and an actionplan is developed to preclude repetition.


None.


None.




NUREG-1 801:

See Item 7, above.

Oyster Creek:



None.


None.




NUREG-1 801:

See Item 7, above.

1D.AshIeI PB B 1.2 Buie pI ping X~ RI I.o PaIcze-I 194I I~I IlT., B.1.26 Burie p Rev O.doc Page 1 OA

Oyster Creek PBD-AMP-B.1 .26, Revision 0License Renewal Project Page 19 of 21Buried Piping Inspection

Oyster Creek:

See Item 7, above.


None.


None.




NUREG-1 801:Operating experience shows that the program described here iseffective in managing corrosion of extemal surfaces of buried steelpiping and tanks. However, because the inspection frequency is plant-specific and depends on the plant operating experience, theapplicant's plant-specific operating experience is further evaluated forthe extended period of operation.

Oyster Creek:

A review of plant operating experience at Oyster Creek shows thatthere has been only one underground leak that developed as aresult of failure of the external portion of buried pipe. In 1992 theService Water system developed a leak that resulted from failure ofthe external coating. The root cause evaluation determined thatfailure was due to improper original coating application.Subsequently, Oyster Creek initiated the Oyster CreekUnderground Piping Program. Additionally, in 1980, 1992 & 1996leaks developed in buried aluminum Condensate Transfer pipe. Asa result 90% of the AL piping was replaced and relocatedaboveground. Subsequently, Oyster Creek initiated the OysterCreek Underground Piping Program in which the inspection andmodifications of the remaining 25 feet of buried AL CondensateTransfer system pipe are tracked. The primary contributor of theburied aluminum pipe at Oyster Creek high corrosion rate isgalvanic corrosion. The galvanic mechanism is primarily due to theinteraction between the aluminum pipe wall and the large copper

e D .. 26 Buried pipinge O.doc Pa 20


grounding grind located on the west side of the plant. Thegrounding grid protects the main transformers and other electricalequipment and lies in the same footprint as the majority of thedirect buried aluminum pipe; before it was replaced by aboveground pipe. The dissimilar metals and moisture in the soil result ina high electrical/chemical potential that drive the galvanic corrosion.Corrosion occurs in local areas where the coating was not properlyapplied or has broken down. By moving the AL pipe toaboveground the aging mechanism of galvanic corrosion concern iseliminated. Additionally, the Oyster Creek Underground PipingProgram tracks the inspection and modifications of the remaining25 feet of buried AL Condensate Transfer system pipe.(Reference: TR-1 16) To date, there have been no other buriedpipe leaks due to external degradation.

Although failure of buried piping has occurred, it has beendetermined that the integrity of the buried piping leaks were causedby degradation of the inside of the buried piping which is evaluatedwith the Open Cycle Closed Cooling Water aging managementprogram. (Reference: PBD-AMP-B.1.13) The existing BuriedPiping Inspection aging management program has identified theloss of material due to general corrosion, pitting, crevice corrosionand microbiologically-influenced corrosion (MIC) of ferrousmaterials and change in material properties on the externalsurfaces of buried pipe. The experience at Oyster Creek with theBuried Piping Inspection program shows that the Buried PipingInspection program is effective in managing loss of material due togeneral corrosion, pitting, crevice corrosion and microbiologically-influenced corrosion (MIC) of ferrous materials and change inmaterial properties on the external surfaces of buried pipe.

Operating experience, both internal and external, is used in twoways at Oyster Creek to enhance plant programs, prevent repeatevents, and prevent events that have occurred at other plants fromoccurring at Oyster Creek. The first way in which operatingexperience is used is through the Oyster Creek OperatingExperience process. The Operating Experience process screens,evaluates, and acts on operating experience documents andinformation to prevent or mitigate the consequences of similarevents. The second way is through the process for managingprograms. This process requires the review of program relatedoperating experience by the program owner.

Both of these processes review operating experience from bothexternal and internal (also referred to as in-house) sources.

[D.Ashley - PBD B.1 .26 Buried piping Rev 0.doc PaQe2l1t1wi1g6 Rev 0.doc 'Page 21'"I


External operating experience may include such things as INPOdocuments (e.g., SOERs, SERs, SENs, etc.), NRC documents(e.g., GLs, LERs, INs, etc.), General Electric documents (e.g.,RCSILs, SILs, TILs, etc.), and other documents (e.g., 10CFR Part21 Reports, NERs, etc.). Internal operating experience mayinclude such things as event investigations, trending reports, andlessons learned from in-house events as captured in programnotebooks, self-assessments, and in the 10 CFR Part 50, AppendixB corrective action process.

Demonstration that the effects of aging are effectively managed isachieved through objective evidence that shows that loss ofmaterial is being adequately managed in the Buried PipingInspection program. The following examples of operatingexperience provide objective evidence that the Buried PipingInspection program is effective in assuring that intended function(s)will be maintained consistent with the CLB for the period ofextended operation:

1. Oyster Creek has performed numerous external inspections oftheir buried components between 1991 and present day. Theresults of these inspections have shown no significant externalcoating failures. Coatings have been repaired during theseinspections in accordance with corporate procedures.(Reference: TR-116)

2. In 2004 50% of the buried ESW and 10% of SW piping werereplaced with new, coated piping. Oyster Creek is planning toreplace the other 50% of the ESW buried piping prior toentering the period of extended operation, with subsequent SWreplacements to follow. (Reference: TR-116)

3. In 1993 an inspection of 20 feet of RBCCW was performed andthe results showed that the external coating was in goodcondition..

4. In 1992 the Fire Protection system underground piping wasinspected via excavation and some internal inspection. TheExternal coating was in good condition as well as the internalcarbon steel. (Reference: TR-1 16)

5. In 1980 the uncoated aluminum underground piping in thevicinity of the Condensate Storage Tank was replaced. In 1991and 1994 buried piping adjacent to the Condensate transfershack was determined to have severe corrosion during an

F D. Ashlev - PBD- B.1.26 Buried piping Rev O.doc Pag -22D. Ahle - PD B1 .6 BuiedDi~ia Rv Odoc aae22

Oyster Creek PBD-AMP-B.1.26, Revision 0License Renewal Project Page 22 of 21Buried Piping Inspection J

inspection. As a result, a significant modification was performedwhich relocated aluminum piping aboveground, in tunnels orvaults. Currently 90% of all AL piping is located aboveground.The remaining buried AL pipe was inspected in 1993 and hasan expected service life of 15-20 years. Action RequestA2116126 has been submitted to perform and inspection of theremaining buried, uncoated AL pipe prior to December 2008.The remaining buried AL piping does have cathodic protection.(Reference: TR-1 16)

The operating experience of the Oyster Creek Buried PipingInspection program has shown objective evidence that the programhas identified susceptible buried pipe locations and has created anmonitoring program that has been effective in preventing failuresprior to the loss of system intended function.

The operating experience of the Buried Piping Inspection programdid not show any adverse trend in performance. Problemsidentified would not cause significant impact to the safe operationof the plant, and adequate corrective actions were taken to preventrecurrence. There is sufficient confidence that the implementationof the Buried Piping Inspection program will effectively determineloss of material due to the manage the effects of corrosion on thepressure-retaining capacity of buried piping. Appropriate guidancefor reevaluation, repair or replacement is provided for locationswhere loss of material was identified. Periodic self-assessments ofthe Buried Piping Inspection program are performed to identify theareas that need improvement to maintain the quality performanceof the program.

3.10 Oyster Creek:

The Oyster Creek Buried Piping Inspection aging managementprogram is credited for managing manage the effects of loss ofmaterial due to corrosion on the pressure-retaining capacity ofburied carbon steel piping for the systems, components, andenvironments listed in Table 5.2. The Oyster Creek Buried PipingInspection program's elements have been evaluated againstNUREG-1 801 in Section 3.0. Program exceptions have beenidentified in Section 2.3. Program enhancements have beenidentified in Section 2.4. The implementing documents for thisaging management program are listed in Table 5.1. The relevantoperating experience has been reviewed and a demonstration ofprogram effectiveness is provided in Section 3.10.

e turi e p in ev 0.oc D. Ahle - PD Bi .6 Buiedpipng Rv OdocPacie 23j


Based on the above, the continued implementation of the OysterBuried Piping Inspection aging management program providesreasonable assurance that the effects of loss of material due tocorrosion on the pressure-retaining capacity of buried carbon steelpiping is adequately managed so that the intended functions ofcomponents within the scope of license renewal will be maintainedduring the period of extended operation.

4.0 REFERENCES





4.1.4 NUREG-1 801, Generic Aging Lessons Leamed (GALL)Report, Revision 1, dated September 2005


4.2.1 EPRI 1003103, Guidelines on NuclearSafety-RelatedCoatings, November 2001.


4.3.1 TDR-829, Inspection History of OCNGS Pipe IntegrityProgram

4.3.2 Topical Report 116, Oyster Creek Underground PipingProgram Description and Status

5.0 TABLES

5.1 Aging Management Program Implementing Documents

Procedure Procedure Title Commitment StatusI Number I I No. I l

.."111-1- - �1--��,�-1-1�-I'll�,,�-�""",�",,,-, ......... --- . ....... .---- I I �.~ .Ahe PB B..2-Bre bnRv d -Pagae 2-4-

I D. Ashley - PBD B.1.26 Buried pi�ina Rev 0.doc Pace 241



ST41401 B Service Water 330592.26.01 ACC/AS(641.4.001) Pump 1-2 IST w/ G

vibrationsST41401A Service Water 330592.26.06 ACC/AS(641.4.001) Pump 1-1 IST w/ G

vibrationsST44402E COND TRANSFER 330592.26.02 ACC/AS(644.4.002) PUMP 'A' G

COMPREHENSIVE TEST (IST)

ST44402F COND TRANSFER 330592.26.03 ACC/AS(644.4.002) PUMP 'B' G

COMPREHENSIVE TEST (IST) X

TDR-829 Inspection History 330592.26.04 ACC/ASof OCNGS Pipe GIntegrity Program

Topical Report Emergency Service 330592.26.05 ACC/AS140 Water and Service G

Water Piping PlanPM******* (new) New PM for 10 330592.26.07 ACC/AS

year inspections GSA-AA-1 17 Excavation, 330592.26.08 ACC/AS

Trenching, and GShoring

Topical Report Oyster Creek 330592.26.09 ACC/AS116 Underground G

Piping ProgramDescription andStatus

ER-AA-330-008 Exelon Service 330592.26.22 ACC/ASLevel I and Safety GRelated (ServiceLevel l1l) ProtectiveCoatings

SP-9000-06-003 Application and 330592.26.23 ACC/ASRepair of Service GLevel II Coatings

SP-9000-06-004 Application and 330592.26.13 ACC/ASRepair of Service GLevel IlIl Coatings

642.4.001 RBCCW Inservice 330592.26.16 ACC/ASTest I G

E D." A's~hIey - P B..D 'B--1;."2-6- ..u6rie'd pipoing Rev O.doc Pae 54D. Ashley~. -PB B12BueD -f Rev O -d Paae - 25- -1-"



607.4.015 Containment Spray 330592.26.17 ACC/ASand ESW System 2 GPump Operability,IST andContainment SprayPumps Trip

607.4.014 Containment Spray 330592.26.18 ACC/ASand ESW System 1 GPump Operability,IST andContainment SprayPumps Trip

ER-AA-330-001 Section Xl 330592.26.24 ACC/ASPressure Testing G

2400-SMM- System Pressure 330592.26.19 ACC/AS3900.04 Test Procedure G

(ASME Xl)645.6.023 Fire Suppression 330592.26.25 ACC/AS

Water System GUnderground FlowTest_

PM10201M Remove Manway 330592.26.20 ACC/ASCover and Inspect GPiping Vault forflooding - Needsenhancement.

[ iD. Ashley - PBD B.1.26 Buried pipingI R~ev O.doc Page, 261 0. Ashley - PBD BA .26 Buried piping Rev O.doc Pacie 26




SSC Name Structure andlor Component Material Environment Aging EffectCondensate Transfer System Piping and fittings Aluminum Soil (External) Loss of MaterialContainment Spray System Piping and fittings Carbon and low alloy steel Soil (External) Loss of MaterialDrywell Floor and Equipment Piping and fittings Carbon and low alloy steel Soil (External) Loss of MaterialDrainsEmergency Service Water Piping and fittings Carbon and low alloy steel Soil (External) Loss of MaterialSystem (w/coating or wrapping) ____

Fire Protection System Piping and fittings Carbon and low alloy steel Soil (External) Loss of MaterialFire Protection System Valve Body Cast Iron Soil (External) Loss of Material

Fire Protection System Valve Body Carbon and low alloy steel Soil (ExtemaJ} Loss of MaterialFire Protection System Fire hydrant Cast Iron Soil (External) Loss of MaterialHeating & Process Steam Piping and fittings Stainless Steel Soil (External) Loss of MaterialSystem l

Heating & Process Steam Piping and fittings | Carbon and low alloy steel Soil (External) Loss of MaterialSystem ____

Miscellaneous Floor and Piping and fittings Carbon and low alloy steel Soil (External Loss of MaterialEquipment Drai System _ _ _ _Reactor Building Closed Piping and fittings Carbon and low alloy steel Soi (External) Loss of Material_Cooling Water System -. .Roof Drains and Overboard Piping and fittings Bronze Soil (Extemal) Loss of MaterialDischarge

Roof Drains and Overboard Piping and fittings Carbon and low alloy steel Soil (External) Loss of MaterialDischarge _ __L___ (w/coating or wrapping) £Service Water System Piping and fittings Carbon and low alloy steel Soil (Extemal) Loss of Material

Service Water System _ Valve Body Carbon and low alloy steel Soil (External) Loss of MaterialSpent Fuel Pool Cooling Piping and fittings j Aluminum Soil (External) Loss of MaterialSystem I X

'Spent Fuel Pool Cooling Piping and fittings Carbon and low alloy steel Soil (External) Loss of MaterialI svstem IS A_... 1_, . ..... -1

! AluminumWater Treatment & Distr. IPiping and fittingsI_

t Soil (Extemnal)_lX Loss of Material

__ _.

[D.Ashley-PBDB.1 .26 Buried piping Rev O.doo Pacje 2711E D Iy. Ashe -BD B.1t.26 Buried pipi _-Rev O.doc Page 27 1



6.0 ATTACHMENTS

6.1 LRA Appendix A

6.2 LRA Appendix B

*i

1.k2 ,1

F67 D.Asle - PB .. BR CR-e~vIO.doc Page' 1 XX .... l...�P. i:::.= ... BWR..SC.Rev.. Paa 1 1

Oyster Creek POD-AMP-B.1.07, Revision 0License Renewal Project ' Page 1 of 27BWR Stress Corrosion Cracking


PBD-AMP-B.1 .07

Revision 0

BWR STRESS CORROSION CRACKING

GALL PROGRAM X1.M7 - BWR STRESS CORROSION CRACKING

Prepared By:

Reviewed By:



Revision History:Revision IPrepared by: Reviewed by: Program Approved by:

Owner:0 Joe Ely S. Rafferty- Greg Harttraft Fred Polaski

CzincilaDate

I I I -:

D. AshlIya BD B. 1.7 BWR SCC Rev O.doc Page 2 4

Oyster CreekLicense Renewal ProjectBWR Stress Corrosion Cracking




D. Ashley - PBD B.1.7 BWR SCC Rev O.doc a

Oyster Creek PBD-AMP-B.1.07, Revision 0License Renewal Project Page 3 of 27BWR Stress Corrosion Cracking

TABLE OF CONTENTS



3.0 EVALUATIONS AND TECHNICAL BASIS 73.1 Scope of Program 73.2 Preventive Actions 93.3 Parameters Monitored or Inspected 123.4 Detection of Aging Effects 133.5 Monitoring and Trending / 143.6 Acceptance Criteria 153.7 Corrective Actions 163.8 Confirmation Process 173.9 Administrative Controls 183.10 Operating Experience 183.11 Conclusion 22

4.0 REFERENCES 224.1 Generic to Aging Management Programs 224.2 Industry Standards 234.3 Oyster Creek Program References 23

5.0 Tables 245.1 Aging Management Program Implementing Documents 245.2 Aging Management Review Results 25

6.0 Attachments 276.1 LRA Appendix A 276.2 LRA Appendix B 27

V6 A" As-hley; ~v~ - P B-D' .1'.7 'B'WR S C C R ev 0. do c Page 6 4 1lU D A le PBDB.1 BW C Rev- O-o Paae 41



1.1 Purpose

The purpose of this Program Basis Document (PBD) is todocument and evaluate those activities of the Oyster Creek BWRStress Corrosion Cracking aging management program that arecredited for managing Cracking Initiation and Growth due tointergranular stress corrosion cracking (IGSCC) in boiling waterreactor (BWR) coolant pressure boundary piping made of stainlesssteel (SS) and nickel alloy as part of Oyster Creek LicenseRenewal to meet the requirements of the License Renewal Rule 10CFR 54, "Requirements for Renewal of Operating Licenses forNuclear Power Plants."

This includes the following:* The identification of the scope of the program;* The evaluation of program elements against NUREG-

1801;* The review of Operating Experience to demonstrate

program effectiveness;* The identification of required program enhancements;

and* The identification of Oyster Creek documents

required to implement the program.

1.2 Methodology

The nuclear power plant License Renewal Rule 10 CFR 54,"Requirements for Renewal of Operating Licenses for NuclearPower Plants," describes the License Renewal process andprovides requirements for the contents of License RenewalApplications. 10 CFR 54.21 (a)(3) states'

"For each structure and component identified in paragraph (a)(1) ofthis section, demonstrate that the effects of aging will beadequately managed so that the intended function(s) will bemaintained consistent with the Current Licensing Basis (CLB) forthe period of extended operation."

The NRC and the industry identified 10 program elements that areuseful in describing an aging management program and thendemonstrating its effectiveness. These program elements are

,6 -kb lbllf.,�� 1. �BWR SC Rev O.doc�z 11 -�t - ---11 I : I 11,1111 - - 1 77 �t . J �,, , , � .z .. 76A

PaqI b. Ashley - PBD B.1 .7 BWR SCC Rev O.doc Paqe 5]

Oyster Creek PBD-AMP-B.11.07, Revision 0License Renewal Project Page 5 of 27BWR Stress Corrosion Cracking t

described in Appendix A.1, Section A.1.2.3 of the Standard ReviewPlan. NUREG-1 801 uses these program elements in Section Xl todescribe acceptable aging management programs.

The purpose of this PBD is to identify and describe the basis forthe BWR Stress Corrosion Cracking aging management programand associated activities credited for managing Cracking Initiationand Growth due to IGSCC in SS and nickel alloy reactor coolantpressure boundary (RCPB) piping, welds and components. ThisPBD also provides a comparison of the credited Oyster Creekprogram with the elements of the corresponding NUREG-1 801Chapter Xl program XI.M7. Project Level Instruction PLI-8"Program Basis Documents" prescribes the methodology forevaluating aging management programs. An evaluation of OysterCreek's aging management program criteria or activities to those ofthe NUREG-1 801 program elements is performed and a conclusionis reached concerning consistency for each individual programelement. A demonstration of overall program effectiveness ismade after all program elements are evaluated. Required programenhancements are documented. An overall determination is madeas to consistency with the program description in NUREG-1 801.



NUREG-1801:

a) The program to manage intergranular stress corrosion cracking(IGSCC) in boiling water reactor (BWR) coolant pressureboundary piping made of stainless steel (SS) and nickel basedalloy components is delineated in NUREG-0313, Rev. 2, andNuclear Regulatory Commission (NRC) Generic Letter (GL) 88-01 and its Supplement 1. The material includes base metal andwelds.

b) The program includes (a) preventive measures to mitigateIGSCC, and

c) (b) inspection and flaw evaluation to monitor IGSCC and itseffects.

d) The staff-approved boiling water reactor vessel and intemalsproject (BWRVIP-75) report allows for modifications to theinspection scope in the GL 88-01 program.

Oyster Creek:

r b. A-s-h-lev, '-'-'P'B--D,-B.1.7 BWR SCC Rev O.doc Page 6 4I D.Ashey -PBDB.1 7 BR 5C Re O~dc Pa.1


a) Oyster Creek has an NRC approved integrated program to\mitigate IGSCC. Oyster Creek addresses the management oCracking Initiation and Growth due to IGSCC in RCPB piping,welds and components through the implementation of ASMESection Xi, "Rules for Inservice Inspection of Nuclear PowerPlant Components." The Oyster Creek IGSCC inspectionprogram has been established for piping identified in NRCGeneric Letter 88-01, and is consistent with the requirements ofNUREG-0313, Rev. 2, and Nuclear Regulatory Commission(NRC) Generic Letter (GL) 88-01 and its Supplement 1. Theprogram includes the alternate measures approved by the NRCin BWRVIP-75, "BWR Vessel and Internals Project TechnicalBasis for Revisions to Generic Letter 88-01 InspectionSchedules." (Reference: OC-2 Program Plan)

b) Water chemistry is controlled through implementation of therecommendations of EPRI BWRVIP-1 30, "BWR Vessel andInternals Project BWR Water Chemistry Guidelines."(Reference: PBD-AMP-B.1.02, Water Chemistry)

c) Inspection and flaw evaluation is conducted in accordance withthe Oyster Creek ISI Program Plan (Reference: OC-1 ProgramPlan) and corporate procedure. (Reference: ER-AA-330-002)Repairs and replacements are controlled by corporateprocedure. (Reference: ER-AA-330-009)

d) The inspection scope identified in GL 88-01 has been modifiedfor the Oyster Creek IGSCC inspection program to reflect thatdefined in the staff-approved BWRVIP-75, "BWR Vessel andInternals Project Technical Basis for Revisions to Generic Letter88-01 Inspection Schedules." (Reference: OC-2 ProgramPlan)


The Oyster Creek BWR Stress Corrosion Cracking agingmanagement program is an existing program that is consistent withNUREG-1 801 aging management program XI.M7 withenhancements as described in 2.4 below.


None. The existing Oyster Creek BWR Stress Corrosion Crackingaging management program is found to be adequate to support theextended period of operation with no exceptions.

[D sly-PBB..WRCRe doPae7IPBD B .7 BWR SCC Rev O.doc _Page 71|



The Oyster Creek BWR Stress Corrosion Cracking agingmanagement program will be enhanced to include:

The program will require that, for those componentswithin the scope of the BWR Stress Corrosion Crackingaging management program, all new and replacementSS materials be low-carbon grades of SS with carboncontent limited to 0.035 wt. % maximum and ferritecontent limited to 7.5% minimum.


Note

This section is organized by quoting the relevant NUREG-1 801 ChapterXl program element (September 2005 version) followed by the relatedOyster Creek program attributes and a conclusion of the comparison.Where applicable, the NUREG-1 801 program element was separatedinto logical sub-elements and addressed accordingly.



NUREG-1 801:a) The program focuses on (a) managing and implementing

countermeasures to mitigate IGSCC and

b) (b) performing inservice inspection (ISI) to monitor IGSCC andits effects on the intended function of BWR components.

c) The program is applicable to all BWR piping and piping weldsmade of austenitic SS and nickel alloy that is 4 in. or larger innominal diameter and contains reactor coolant at a temperatureabove 930C (2000F) during power operation, regardless of codeclassification. The program also applies to pump casings, valvebodies and reactor vessel attachments and appurtenances,such as head spray and vent components.

d) NUREG-0313 and NRC GL 88-01, respectively, describe thetechnical basis and staff guidance regarding mitigation of

12-A- B.D.B.1.7BWRSCC RevO.doc ~D.Ahle-PB BA7BWSCCRevdocPaae 81


IGSCC in BWRs.

e) Attachment A of NRC GL 88-01 delineates the staff-approvedpositions regarding materials, processes, water chemistry, weldoverlay reinforcement, partial replacement, stress improvementof cracked welds, clamping devices, crack characterization andrepair criteria, inspection methods and personnel, inspectionschedules, sample expansion, leakage detection, and reportingrequirements.

Oyster Creek:

a) Oyster Creek has committed to the requirements for mitigatingIGSCC. Reactor coolant water chemistry is monitored andmaintained in accordance with the guidelines in EPRI BWRVIP-130 to maintain high water purity to reduce susceptibility to SCCor IGSCC. (Reference: PBD-AMP-B.1.02, Water Chemistry)

b) The ISI program is described in PBD-AMP-B.1.01, ASMESection Xl Inservice Inspection, Subsections IWB, IWC, andIWD.

c) The scope of the BWR Stress Corrosion Cracking agingmanagement program includes RCPB piping, welds andcomponents, of four inches and larger nominal pipe size, madeof SS and nickel alloy. Pump casings, valve bodies and reactorvessel attachments and appurtenances, such as head sprayand vent components, are also included. (Reference:PBD-AMP-B.1.01, ASME Section Xi Inservice Inspection,Subsections IWB, IWC, and IWD)

d) The Oyster Creek IGSCC inspection program incorporates thetechnical basis and staff guidance described in NUREG-0313and NRC GL 88-01, respectively, modified to reflect thealternate requirements of the staff-approved BWRVIP-75 report.(Reference: PBD-AMP-B.1.01, ASME Section Xl InserviceInspection, Subsections IWB, IWC, and IWD, and Reference:PBD-AMP-B.1.02, Water Chemistry)

e) The Oyster Creek IGSCC inspection program incorporatesapplicable requirements that are consistent with therecommendations of Attachment A of NRC GL 88-01. Theserequirements are reflected in the Oyster Creek ISI and WaterChemistry programs discussed further above and in theappropriate sections throughout this document. (Reference:PBD-AMP-B.1.01, ASME Section Xl Inservice Inspection,Subsections IWB, IWC, and IWD, and Reference: PBD-AMP-B.1.02, Water Chemistry)

D. Asley-PBD B.1.7 BWR SCC Rev O.doc Pagae9



None.


None.


This element is consistent with NUREG-1 801, Element 1, Scope ofProgram.


NUREG-1 801:

The comprehensive program outlined in NUREG-0313 and NRCGL 88-01 addresses improvements in all three elements that, incombination, cause IGSCC. These elements consist of asusceptible (sensitized) material, a significant tensile stress, and anaggressive environment. Sensitization of nonstabilized austeniticSSs containing greater than 0.03 wt. % carbon involvesprecipitation of chromium carbides at the grain boundaries duringcertain fabrication or welding processes. The formation of carbidescreates an envelope of chromium depleted region that, in certainenvironments, is susceptible to stress corrosion cracking (SCC).Residual tensile stresses are introduced from fabricationprocesses, such as welding, surface grinding, or forming. Highlevels of dissolved oxygen or aggressive contaminants, such assulfates or chlorides, accelerate the SCC processes.

a) The program delineated in NUREG-0313, NRC GL 88-01, andin the staff-approved BWRVIP-75 report includesrecommendations regarding selection of materials that areresistant to sensitization, use of special processes that reduceresidual tensile stresses, and monitoring and maintenance ofcoolant chemistry.

b) The resistant materials are used for new and replacementcomponents and include low-carbon grades of austenitic SSand weld metal, with a maximum carbon of 0.035 wt.% and aminimum ferrite of 7.5% in weld metal and cast austeniticstainless steel (CASS). Inconel 82 is the only commonly usednickel-base weld metal considered to be resistant to SCC; othernickel-alloys, such as Alloy 600 are evaluated on an individual

[b.Ash1ev-PBDB.1.7BWRSCC RevO.doc Page 1 0 1V" D. Ashley1__ - B B1. BW -C Re- .o ae1


basis.

c) Special processes are used for existing, new, and replacementcomponents. These processes include solution heat treatment,heat sink welding, induction heating, and mechanical stressimprovement.

d) The program delineated in NUREG-0313 and NRC GL 88-01does not provide specific guidelines for controlling reactor waterchemistry to mitigate IGSCC. Maintaining high water purityreduces susceptibility to SCC or IGSCC. The programdescription, and evaluation and technical basis of monitoringand maintaining reactor water chemistry are addressed throughimplementation of Section XI.M2, 'Water Chemistry.'

Oyster Creek:

a) The Oyster Creek ISI program described in PBD-AMP-B.1.01and the Oyster Creek Water Chemistry program described inPBD-AMP-B.1.02, respectively, incorporate therecommendations regarding selection of materials that areresistant to sensitization and use of special processes thatreduce residual tensile stresses, and monitoring andmaintenance of coolant chemistry, delineated in NUREG-0313,NRC GL 88-01, and the staff-approved BWRVIP-75 report.

b) Resistant materials used at Oyster Creek for new andreplacement components include low-carbon grades of SS.Weld metal carbon content is limited to 0.035 wt. % maximumwith a minimum ferrite of 7.5%. The program will be enhancedto require that, for those components within the scope of theBWR Stress Corrosion Cracking aging management program,all new and replacement SS materials be low-carbon grades ofSS with carbon content limited to 0.035 wt. % maximum andferrite content limited to 7.5% minimum. (Reference: SYS-LL-OC-1, Line Specification Numbers MV-5, MV-5A, NC-4, ND-10A, ND-1OB, ND-1OC, ND-1A, ND-1B, ND-1C, ND-9B, NE-lA,NE-1B, NE-IC, NE-2, NE-5, NU-3, NU-4, NZ-3, RHC-2A, RHC-2B, and SS-1; CC-AA-501-1017, Attachment 1)

c) Special processes such as solution heat treatment and heatsink welding are used. Mechanical Stress ImprovementProcess (MSIP) or Induction Heating Stress Improvement (IHSI)has been used on all assessable welds (Reference: OC-2Program Plan section 3.0).

d) Reactor coolant water chemistry is monitored and maintained in

------- ____

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Oyster Creek PBD-AMP-B.1.07, Revision 0License Renewal Project, Page 11 of 27BWR Stress Corrosion Cracking

accordance with the guidelines in BWRVIP-130, "BWR Vesseland Internals Project BWR Water Chemistry Guidelines" tomaintain high water purity to reduce susceptibility to SCC orIGSCC. Oyster Creek also implemented Hydrogen WaterChemistry in 1992 and Noble Metals in 2002 to further reducesusceptibility of the RCPB piping system to SCC or IGSCC.The program description, evaluation and technical basis ofmonitoring and maintaining reactor water chemistry arepresented in PBD-AMP-B.1.02, Water Chemistry.


None.


The program will be enhanced to require that, for thosecomponents within the scope of the BWR Stress CorrosionCracking aging management program, all new and replacement SSmaterials be low-carbon grades of SS with carbon content limitedto 0.035 wt. % maximum and ferrite content limited to 7.5%minimum.


This element is consistent with NUREG-1 801, Element 2,Preventive Actions, with enhancements as described above.


NUREG-1 801:The program detects and sizes cracks and detects leakage, byusing the examination and inspection guidelines delineated inNUREG-0313, Rev. 2, and NRC GL 88-01 or the referencedBWRVIP-75 guideline as approved by the NRC staff.

Oyster Creek:

Augmented examination requirements for IGSCC are conducted inaccordance with the Oyster Creek ISI Program Plan. These arebased on the examination and inspection guidelines delineated inNUREG 0313, Rev. 2, and GL 88-01. Oyster Creek implementsBWRVIP-75 to apply a technical evaluation approach applicable tothe materials and degradation mechanisms of systems to justify theexamination criteria. (Reference: OC-2 Program Plan section4.0)

FD. Ashle-y - PBD B.1.7 BWR S0C Rev 0.doc Page 12I 0. Ashley - PBD B.1 .7 BWR Soc Rev 0.doc Page 12�I



None.


None.


This element is consistent with NUREG-1 801, Element 3,Parameters Monitored or Inspected.


NUREG-1 801:

a) The extent, method, and schedule of the inspection and testtechniques delineated in NRC GL 88-01 or BWRVIP-75 aredesigned to maintain structural integrity and ensure that agingeffects will be discovered and repaired before the loss ofintended function of the component. The inspection guidance inapproved BWRVIP-75 replaces the extent and schedule ofinspection in NRC GL 88-01.

b) The program uses volumetric examinations to detect IGSCC.

c) NRC GL 88-01 recommends that the detailed inspectionprocedure, components, and examination personnel bequalified by a formal program approved by the NRC. Theseinspection guidelines, updated in the approved BWRVIP-75document, provide the technical basis for revisions to NRC GL88-01 inspection schedules. Inspection can reveal cracking andleakage of coolant.

d) The extent and frequency of inspection recommended by theprogram are based on the condition of each weld (e.g., whetherthe weldments were made from IGSCC-resistant material,whether a stress improvement process was applied to aweldment to reduce residual stresses, and how the weld wasrepaired if it had been cracked).

Oyster Creek:

a) The extent, method, and schedule of inspection and testtechniques are in accordance with the ISI Program Plan atOyster Creek. Augmented examination requirements forIGSCC are also in accordance with the ISI Program Plan at

BD B.. WRSCRe 2 o D Page 13


Oyster Creek. The Oyster Creek ISI Program Plan incorporatesthe guidance delineated in NRC GL 88-01 and BWRVIP-75.(Reference: OC-2 Program Plan)

b) Ultrasonic examinations of piping welds susceptible to IGSCCare conducted in accordance with commitments associated withGL 88-01. (Reference: OC-2 Program Plan)

c) Oyster Creek's augmented inspection program for IGSCC isincorporated in the Oyster Creek ISI program, a formal programthat is periodically reviewed and approved, in accordance withthe requirements of 10 CFR 50.55a, by the NRC. The IGSCCinspection guidelines conform to the recommendations of NRCGL 88-01, as updated by the approved BWRVIP-75 document,and variances from the NRC staff positions are reviewed andapproved by the NRC. Personnel performing ultrasonic testing(UT) on applicable Reactor Vessel and piping welds for ASMESection Xl are qualified to the requirements Appendix VIII ofSection Xl, applicable Edition and Addenda, or to the alternativerequirements approved by the NRC. (Reference: OC-1Program Plan; OC-2 Program Plan)

d) Oyster Creek's augmented inspection program for IGSCCconforms to the NRC positions on inspection schedules,methods, personnel, and sample expansion delineated inGeneric Letter 88-01. Any variances from the NRC staffpositions are reviewed and approved by the NRC. (Reference:OC-2 Program Plan)


None.


None.


This element is consistent with NUREG-1 801, Element 4, Detectionof Aging Effects.


NUREG-1 801:

The extent and schedule for inspection, in accordance with the

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recommendations of NRC GL 88-01 or approved BWRVIP-75guidelines, provide timely detection of cracks and leakage ofcoolant. Based on inspection results, NRC GL 88-01 or approvedBWRVIP-75 guidelines provide guidelines for additional samples ofwelds to be inspected when one or more cracked welds are foundin a weld category.

Oyster Creek:

The extent and schedule of augmented tests and examinations arein accordance with the ISI Program Plan at Oyster Creek, whichincludes guidelines for reportable indication resolution, additionalexamination, and successive examination in accordance with NRCGL 88-01 and BWRVIP-75 guidelines. (Reference: OC-1Program Plan; ER-AA-330-002; ER-AA-330-009)


None.


None.


This element is consistent with NUREG-1 801, Element 5,Monitoring and Trending.


NUREG-1 801:-a) As recommended in NRC GL 88-01, any indication detected is

evaluated in accordance with ASME Section Xl, IWB-3600 ofSection Xl of the 1986 Edition of the ASME Boiler and PressureVessel Code and the guidelines of NUREG- 0313.

b) Applicable and approved BWRVIP-14, BWRVIP-59, BWRVIP-60, and BWRVIP-62 documents provide guidelines forevaluation of crack growth in SSs, nickel alloys, and low-alloysteels. An applicant may use BWRVIP-61 guidelines for BWRvessel and intemals induction heating stress improvementeffectiveness on crack growth in operating plants.

Oyster Creek:

a) Relevant conditions detected during examinations are evaluated

.7 BWR SCC Rev . oc Page 15


in accordance with ASME Section Xl Articles IWB-3000, forClass 1. The ASME Section Xl portion of the program currentlycomplies with the requirements of the 1995 Edition through1996 Addenda of the ASME Code, Section Xl, "Rules forInservice Inspection of Nuclear Power Plant Components," andis implemented through facility procedures. (Reference: OC-1Program Plan, OC-2 Program Plan, ER-AA-330-002, andProcedure ER-AA-330-009)

b) If the flaw does not meet the acceptance criteria of IWB-3600,repairs or replacements are accomplished in accordance withapplicable Section Xl rules and requirements. When a flawexceeds the applicable acceptance standards of IWB-3500 acondition report is initiated in accordance with applicableprocedures. An analytical evaluation is performed inaccordance with IWB-3600 to determine its acceptability forcontinued service without repair or replacement. This analyticalevaluation shall be submitted to the NRC Staff for approvalbefore resumption of operation. (Reference: ER-AA-330-002section 4.12.4) These criteria are consistent with theguidelines of BWRVIP-14, -59, -60, -61, and -62. MechanicalStress Improvement Process (MSIP) or Induction HeatingStress Improvement (IHSI) has been used on all assessablewelds. (Reference: OC-2 Program Plan section 3.0)


None.


None.


This element is consistent with NUREG-1 801, Element 6,Acceptance Criteria.


NUREG-1 801:The guidance for weld overlay repair and stress improvement orreplacement is provided in NRC GL 88-01; ASME Section Xl,Subsections IWB-4000 and IWB-700D, IWC-4000 and IWC-7000,or IWD-4000 and IWD-7000, respectively for Class 1, 2, or 3components; and ASME Code Case N-504- 1. As discussed in the

D. BDsh1e7BWRSCC Rev 0.docPae6


NUREG-1801, Rev. 1 Xl M-28 September2005 appendix to thisreport, the staff finds the requirements of 10 CFR Part 50,Appendix B, acceptable to address the corrective actions.

Oyster Creek:

If the flaw does not meet the acceptance criteria of IWB-3600,repairs or replacements are accomplished in accordance withapplicable Section Xl rules and requirements. (Reference: ER-AA-330-002; ER-AA-330-009) Evaluations are performed forinspection results that do not satisfy established criteria and acondition report is initiated to document the concern in accordancewith plant administrative procedures. The corrective actionprogram ensures that the conditions adverse to quality are promptlycorrected. If the deficiency is assessed to be significantly adverseto quality, the cause of the condition is determined and an actionplan is developed to preclude recurrence.


None.


None.



3.7 Confirmation Process .

NUREG-1 801:

Site quality assurance (QA) procedures, review and approvalprocesses, and administrative controls are implemented inaccordance with the requirements of 10 CFR Part 50, Appendix B.As discussed in the appendix to this report, the staff finds therequirements of 10 CFR Part 50, Appendix B, acceptable toaddress the confirmation process and administrative controls.

Oyster Creek:


I

Lq� �ey BW R SCC Rev O.doc 19S1in: P.=.== Ashley-PB B.1.7BWRSCC Rev 0;.do _ai 171sm,




None.


None.




NUREG-1 801:

See Item 8, above.

Oyster Creek:

See Item 3.8, above.


None.


None.




NUREG-1 801:

Intergranular stress corrosion cracking has occurred in small- andlarge-diameter BWR piping made of austenitic stainless steel andnickel-base alloys. Cracking has occurred in recirculation, corespray, residual heat removal (RHR), control rod drive (CRD) returnline penetrations, and reactor water cleanup (RWCU) systempiping welds (NRC GL 88-01, NRC Information Notices [INs] 82-39,84-41, and 04-08). The comprehensive program outlined in NRCGL 88-0 1, NUREG-0313, and in the staff-approved BWRVIP-75

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Oyster Creek -PBD-AMP-B.1.07, Revision 0License Renewal Project Page 18 of 27BWR Stress Corrosion Cracking

report addresses mitigating measures for SCC or IGSCC (e.g.,susceptible material, significant tensile stress, and an aggressiveenvironment). The GL 88-01 program has been effective inmanaging IGSCC in BWR reactor coolant pressure-retainingcomponents and the revision to the GL 88-01 program, accordingto the staff-approved BWRVIP-75 report, will adequately manageiGSCC degradation.

Oyster Creek:

Review of industry operating experience has confirmed that IGSCChas occurred in the small- and large-diameter BWR piping made ofaustenitic stainless steel and nickel-base alloys, and that suchcracking has occurred in recirculation, core spray, residual heatremoval (RHR), control rod drive (CRD) return line penetrations,and reactor water cleanup (RWCU) system piping welds (NRC GL88-01, NRC Information Notices [INs] 82-39, 84-41, and 04-08). Areview of plant operating experience at Oyster Creek shows thatIGSCC occurred in the Core Spray, Reactor Recirculation, andShutdown Cooling systems. In most cases, the existing BWRStress Corrosion Cracking aging management program hasidentified the IGSCC prior to leaks occurring. However, there havebeen some cases where through wall leakage as a result of IGSCCwas identified during pressure testing. As a result of these pipefailures, the BWR SCC program was modified to improve waterchemistry, de-sensitize the susceptible materials, and moreaccurately identify susceptible locations prior to failure. Theexperience at Oyster Creek with the BWR SCC program showsthat the BWR SCC program is effective in managing IGSCC inaustenitic stainless steel and nickel-base alloy RCPB piping andcomponents.

Operating experience, both internal and extemal, is used in twoways at Oyster Creek to enhance plant programs, prevent repeatevents, and prevent events that have occurred at other plants fromoccurring at Oyster Creek. The first way in which operatingexperience is used is through the Oyster Creek Operating>Experience process. The Operating Experience process screens,evaluates, and acts on operating experience documents andinformation to prevent or mitigate the consequences of similarevents. The second way is through the process for managingprograms. This process requires the review of program relatedoperating experience by the program owner.

Both of these processes review operating experience from bothexternal and internal (also referred to as in-house) sources.

LD. AshleBy.ZJM - PBD B.BWSo Rev Dd Page 1


External operating experience may include such things as INPOdocuments (e.g., SOERs, SERs, SENs, etc.), NRC documents(e.g., GLs, LERs, INs, etc.), Westinghouse documents (e.g., TBs,etc.), General Electric documents (e.g., RCSILs, SILs, TILs, etc.),and other documents (e.g., 10 CFR Part 21 Reports, NERs, etc.).Internal operating experience may include such things as eventinvestigations, trending reports, and lessons learned from in-houseevents as captured in program notebooks, self-assessments, andin the 10 CFR Part 50, Appendix B corrective action process.

Demonstration that the effects of aging are effectively managed isachieved through objective evidence that shows that cracking dueto IGSCC is being adequately managed in the RCPB piping andcomponents. The following examples of operating experienceprovide objective evidence that the BWR SCC program is effectivein assuring that intended function(s) will be maintained consistentwith the CLB for the period of extended operation:

1) Of the 380 welds in the GL 88-01 scope, including 85 in theRWCU system outside the second containment isolation valves,Oyster Creek eventually identified, during the period theprogram was being implemented, 11 welds in service withindications of IGSCC. Nine were repaired with full structuraloverlays (four in the Core Spray system, four in the ReactorRecirculation system, and one in the Shutdown Coolingsystem). Two Reactor Recirculation system welds, which wereboth stress improved before initial inspections determinedindication of IGSCC, remained in service without repair.However, subsequent to implementation of the NRC approvedPerformance Demonstration Initiative (PDI), inspectionsperformed in 2002 and 2004 using the improved PDIexamination technique determined these welds did not exhibitany indication of IGSCC. Oyster Creek, therefore, does notcurrently have any indication of IGSCC. This example providesobjective evidence that the program's repair and stressimprovement techniques are effective in mitigating the effects ofIGSCC, and that the continually improving inspectiontechniques have been effective in conservatively identifyingIGSCC.

2) To date, IGSCC indication has been found in 40 welds.Following numerous piping replacements 11 welds withindications of IGSCC remained in service. As discussed above,nine of the eleven welds were repaired with full structuraloverlays, and the remaining two were determined, afterimplementation of improved PDI inspection techniques, to be

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Oyster Creek PBD-AMP-B1.11.07, Revision 0License Renewal Project Page 20 of 27BWR Stress Corrosion Cracking

free of IGSCC indication. No new indications of IGSCC havebeen detected by inspection during the last six (6) outages.This example provides objective evidence that the Oyster CreekBWR Stress Corrosion Cracking aging management programhas been effective in both detecting and mitigating the effects ofIGSCC.

3) Since Generic Letter 88-01 was issued, Oyster Creek hasperformed numerous examinations on piping subject to thegeneric letter requirements. During this period, Oyster Creekhas improved water chemistry and employed stressimprovement and Hydrogen Water Chemistry (HWC) as IGSCCmitigators (HWC was implemented in 1992). In addition,examination procedures have been improved and examinationpersonnel have received training on the latest techniques forIGSCC detection and have gained years of experience in thedetection and sizing of IGSCC. This example provides furtherobjective evidence that the Oyster Creek BWR Stress CorrosionCracking aging management program is subject to continuingimprovement through the effective determination andimplementation evolving methods for detecting and mitigatingthe effects of IGSCC.

4) From 1988 to 2000, during pressure testing of the Core Spraysystem, three indications of through wall leakage wereidentified, and in 1991 three other IGSCC indications wereidentified by UT examination. One of the through wallindications was found in a low temperature (non GL 88-01)location. This weld was repaired with a full weld overlay. Theseare additional examples of the effectiveness of the program foridentifying and correcting the effects of IGSCC well before lossof the affected systems' intended function(s) occurs.

5) In 1991, all Isolation Condenser large bore piping outside thedrywell (from the drywell penetrations to the IsolationCondensers) that has been susceptible to IGSCC was replacedwith IGSCC resistant material, and all new welds were stressimproved. All piping within the four Isolation Condenser drywellpenetrations and the two RWCU system drywell penetrations,which contain welds that are not accessible, were also replacedwith IGSCC resistant material. Piping at the IsolationCondensers on 95' elevation was also replaced with IGSCCresistant material in 1998, and the Head Cooling Spray NozzleAssembly, the 4-inch tee and flange of the reactor vent linehave also been replaced. These replacements have reducedthe number of susceptible welds. This example objectively

0 D. Ashley - PBD B.1.7 BWR SCC Rev O.doc2 <>>aid-0- - I


demonstrates the proactive nature of the program throughpreventive repair and replacement of susceptible piping beforea potential loss of the affected systems' intended function(s)can occur.

6) All accessible welds inside the drywell (except the RWCUsystem) have been stress improved. Zinc injection wasimplemented in 2000, and Noble Metal Chemical Addition(NMCA) was implemented in 2002. This is further objectiveevidence of the program's proactive preventive nature.

The operating experience of the BWR SCC program did not showany adverse trend in performance. Problems identified would notcause significant impact to the safe operation of the plant, andadequate corrective actions were taken to prevent recurrence.There is sufficient confidence that the implementation of the BWRSCC program will effectively manage the effects of cracking due toIGSCC in austenitic stainless steel and nickel-base alloy RCPBpiping and components. Appropriate guidance for reevaluation,repair, or replacement is provided for locations where inspectionsreveal indication of the onset of IGSCC that could lead to failure ofthe component prior to the next scheduled inspection. Periodic self-assessments of the BWR SCC program are performed to identifythe areas that need improvement to maintain the qualityperformance of the program.

3.10 Conclusion

The Oyster Creek BWR Stress Corrosion Cracking agingmanagement program is credited for managing cracking initiationand growth due to IGSCC in SS and nickel alloy for the systems,components, and environments listed in Table 5.2. The OysterCreek BWR Stress Corrosion Cracking aging managementprogram's elements have been evaluated against NUREG-1 801 inSection 3.0. Program exceptions have been identified in Section2.3. Program enhancements have been identified in Section 2.4.The implementing documents for this aging management programare listed in Table 5.1. The relevant operating experience hasbeen reviewed and a demonstration of program effectiveness isprovided in Section 3.10.

Based on the above, the continued implementation of the OysterCreek BWR Stress Corrosion Cracking aging managementprogram provides reasonable assurance that cracking initiation andgrowth due to IGSCC in SS and nickel alloy RCPB piping, weldsand components will be adequately managed so that the intended

D. Ashley-PBD B.1.7 BWR SCC Rev O.doc:'I~z ~ _.,.f.,S:...=.:. A. Y.5.f.A.tba. A Cw.i.5

Page 223


functions of components within the scope of license renewal will bemaintained during the period of extended operation.

4.0 REFERENCES


4.1.1 10 CFR 50, Appendix B, Quality Assurance Criteria forNuclear Power Plants and Fuel Reprocessing Plants



4.1.4 NUREG-1 801, Genetic Aging Lessons Learned (GALL)Report, Revision 1, dated September 2005


4.2.1 NRC Generic Letter 88-01, "NRC Position on IGSCC inBWR Austenitic Stainless Steel Piping," U.S. NuclearRegulatory Commission, January 25,1988; Supplement 1,February 4,1992.

4.2.2 NUREG-0313, Rev. 2, "Technical Report on MaterialSelection and Processing Guidelines for BWR CoolantPressure Boundary Piping," W. S. Hazelton and W. H. Koo,U.S. Nuclear Regulatory Commission, 1988.

4.2.3 BWRVIP-75, "BWR Vessel and Internals Project TechnicalBasis for Revisions to Generic Letter 88-01 InspectionSchedule," October 1999

4.2.4 ASME Boiler and Pressure Vessel Code, Section Xl, "Rulesfor In-service Inspection of Nuclear Plant Components,"1995 Edition through 1996 Addendum


4.3.1 Document Number OC-1, Rev. 1 "ISI Program Plan, OysterCreek Nuclear Generating Station, Fourth Interval"

4.3.2 Amergen Letter No. 2130-02-20228 dated August 1, 2002"Proposed Alternatives and Relief Request to the

D.Ashley 1 PBD B1..7 BWR SCC Rev 0.doc Paa 2


Requirements of 1 OCFR5055a Concerning the Fourth Ten-Year Interval Inservice Inspection Program and ProposedAlternative to Containment Inspection Program"

4.3.3 Amergen Letter No. 2130-03-30262 dated September 26,2003, "Alternatives and Reliefs Concerning the Fourth 10-Year Interval Inservice Inspection Program"

4.3.4 Document Number OC-2, Rev. 0, "IGSCC InspectionProgram (Generic Letter 88-01 and BWRVIP-75)"

4.3.5 GPU Nuclear Letter No. 5000-89-1712 dated January 31,1989 "Generic Letter 88-01 (TR-050 Rev. 1, GPUNResponse to Generic Letter 88-01 and NUREG 0313, Rev.2)"

4.3.6 GPU Nuclear Letter No. 5000-90-1938 dated June 7,1990"Generic Letter 88-01"

4.3.7 GPU Nuclear Letter No. 1940-98-20418 dated July 29,1998"Request for Approval of Alternate 17R Outage InspectionsRelated to Generic Letter 88-01 Intergranular StressCorrosion Cracking (IGSCC) Commitments"

4.3.8 GPU Nuclear Letter No. 1940-98-30611 dated October 14,1998 "Reduced Scope of Intergranular Stress CorrosionCracking (IGSCC) Inspection for Oyster Creek NuclearGenerating Station During Refueling Outage

4.3.9 OC-IS-402585-001, Rev. 5, "Installation Specification forRepair and Replacement of Reactor Coolant Systems PipingOyster Creek Nuclear Generating Station"

4.3.10 LS-OS-1 25, "Corrective Action Program (CAP) Procedure"

5.0 TABLES

5.1 Aaing Management Program Implementing DocumentsProcedure Procedure Title Commitment Status

Number No.OC-2 Program IGSCC Inspection Program (Generic 330592.07.01 ACC/ASGPlan Letter 88-01 and BWRVIP-75)OC-1 Program ISIProgram Plan Fourth Ten-Year 330592.07.02 ACC/ASGPlan Inspection IntervalER-AA-330- Inservice Inspection of Section Xl 330592.07.03 ACC/ASG002 Welds and Components I

.- Z - -� , - --11-1- 1-1- I - I I I - x - II DAshey-BD B.1 .7 BWR SCC Rev O~doc - Page 241



ER-AA-330- ASME Section Xl 330592.07.04 ACC/ASG009 Repair/Replacement ProgramSYS-LL-OC-1 Line List and Specification 330592.07.05 ACC/ASGCC-AA-501- Welding Filler Material Procurement 330592.07.06 ACC/ASG1017 Requirements

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V D. Ashlev - P'BD B.1.7 13WR sCC Rev 0.doc Page 251[D. Ashley - PBD B.1 .7 BWR Soc Rev O.doc Page 251



5.2 Aninn MananemAnt Review ResultsSSC Name [ Structure and/or Component Material Environment_ __AgIngEffect__

Core Spray System Valve Body CASS Treated Water (Internal) Cracking Initiation and__.._ _._ _ __ _ ____ . Growth

Core Spray System Piping and fittings Stainless Treated Water (Internal) Cracking Initiation and_ _ Steel Growth

Core Spray System Valve Body Stainless Treated Water (Internal) Cracking Initiation and. Steel Growth

Isolation Condenser Valve Body CASS Steam (Internal) Cracking Initiation andSystemGrowthIsolation Condenser Piping and fittings Stainless Steam (Internal) Cracking Initiation andSystem _ ____ __ Steel GrowthIsolation Condenser Piping and fittings Stainless Treated Water (Internal) Cracking Initiation andsstem Steel GrowthIsolation Condenser Valve Body CASS Treated Water (Internal) Cracking Initiation andSvstem GrowthIsolation Condenser Valve Body Stainless Treated Water (Internal) ' Cracking Initiation andSystem Steel GrowthIsolation Condenser Valve Body Stainless Steam (itemao I Cracking Initiation andSystem i Steel n GrowthNuclear Boiler Piping and fittings Stainless Treated Water (Internal) Cracking Initiation andInstrumentation . _______ Steel ; _ GrowthReactor Pressure Vessel Nozzle Safe Ends (RecirculationInlet&Outlet) Stainless Treated Water (Internal) Cracking Initiation and

St __ eel GrowthReactor Pressure Vessel t Nozzle Safe Ends (Core Spray Isolation Stainless Treated Water (Internal) Cracking Initiation and

'Condenser & CRD RetuSr) Steel GrowthReactor Recirculation Flow Element Stainless iTreated Water (Intemal) .Cracking Initiation andSystem Steel - GrowthReactor Recirculation Piping and fittings Stainless i Treated water (Interal) i Uracking Initation andSys m L. Steel GrowthReactor Recirculation Pump Casing CAS Treated Water >482F Cracking Initiation andSystem (_ _ _ __ _ Intema_ _ ._GrowthReactor Recirculation Valve Body CASS Treated Water >482F Cracking Initiation and

I ystem , I (ntemal GrowthReactor Recirculation Valve Body Stainless Treated Water (Internal) Cracking Initiation andSvstem Steel Growth 1

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I [D. Ashlev - PBD B.1.7 BWR ScC Rev O.doc Paqe 26 1



Reactor Water Cleanup Piping and fittings Stainless Treated Water (Internal) Cracking Initiation andSvster Steel GrowthReactor Water Cleanup Valve Body CASS Treated Water >482F Cracking Initiation and

W Cyste e .Va Bte d W trGrowthReactor Water Cleanup Vave Body Siess Treated Water (Intenal) Cracking Initiation and

Sytm.Steel GrowVthShutdown Cooling System Valve Body Stainless Treated Water (Internal) Cracking Initiation and

Steel I GrowthShutdown Cooling System Piping and fittings Stainless Treated Water (Internal) Cracking Initiation and

Steel I Growth

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6.0 ATTACHMENTS

6.1 LRA Appendix A

6.2 LRA Appendix B

. B. 1.1 ASME Section Xi Inservice Inspection, Subsections IWB, IWC and IWOB 1.2 Water Chemistry

: B.3 Reactor Head Closure StudsB.1.4 BWR Vessel ID Attachment WeldsB1J.5 8WR Feedwater NozzleS. 1.6 8WR Control Rod Drive Return Line Nozzle81.7 BWR Stress Corrosion Cracking81.8 SWR PenetrationsB.1.10 Thermal Aging and Neutron Irradiation Embrlltlement of Cast Austenitic Stainless Steel (CASS)B.1.11 Flow-Accelerated CorrosionB.1.13 Open-Cycle Cooling Water System8.1.14 Closed-Cycle Cooling Water SystemB.1.15 Braflex Rack Management Program8.1.16 Inspection of Overhead Heavy Load and Llght Load (Related to Refueling) Handring Systems8.1.17 Compressed Air MonitoringB. 1.18 BWR Reactor Water Cleanup SystemB .1.19 Fire ProtectionB.1.20 Fire Water System

C n B1.21 Aboveground Outdoor TanksO.1.22Fuel Oil Chemistry

C rnB.1.24 One-Time InspectionC 8.1.25Selective Leaching of Materials0 8 1.26 Burled Piping InspectionCLn .1.27 ASME Seclion Xl Subsection IWEO) .8.1.28 ASME Section Xl, Subsection IWF

c 8.1.2910 CFR Part 60, Appendix J1 B.1.30 Masonry Wall Program

8.1.31 Structures Monitoring Program8.1.32 RG 1.27, InspectIon of Water-Control Structures Associated wIth Nuclear Power Plants.L 8.1.33 Protective Coating Monitoring and Maintenance Program

2 .1.34 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualiflcation Requirements< 8.1.35 Electrical Cables and Connections Not Subject to 10 CFR 60.49 Environmental Oualification Requirements Used in Instrum1entation CIrcuitso 8.1.36 Inaccessible Medium Voltage Cables Not Subject to 10 CFR 60.49 Erwironmental Qualirfcation RequirementsY 8.3.1 Metal Fatigue of Reactor Coolant Pressure BoundaryO) B3.2 Environmentea Qualification EQ Prog

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Pits is ready for NRC review, thit Bet wiUl be transmitted. This way, the NRC Audit team can continue their reviews while the Oyster Creek teem continues to generate the upgraded PS. Thesetransmittals are being made an an ongoing activity as past of the AMP Audit

11/17/05 Update

The Initial (two) PBDs provided to the NRC were the Flow Accelerated Corrosion (FAC) and the Reactor Water Cleanup (RWCU) PBDs. These were s-mailed to NRC Project Manager DotnbeAshley. with a copy to Audit Team lead Greg Cranston, on 11117105. They were provided In two formats. POF versions of the documenta were provided, which Included copies of the signatures ofthe preparer, reviewer, program owner (site) and Approver (Project Technical Lead). In addition, as requested by the NRC, Word versions were provided to facilitate the Audit review and reportwriting process.-J.G. Hulnagel

11/28/O Update (J.G. Hulunagel)

| Today, 11/28(05, electronic copies (in Word format) of the following approved AMP Basis Docmnenrt (PBOs) were provided via e-mail to the NRC Projot Manager and NRC AMP/AMR Audit teamlead: 8.1.02 (Water Chemistry), 8.1.22 (Fuel Oil Chemistry), 8.1.08 (BWR Penetrations), B.1.19 (Fire Protection). 8t.1.31 (Structures Monitoring), B.1 01 (ASME Section Xi IW3. IWC, iWD), 8.1.17(Compressed Air) and B.1.25 (Selective Leaching). They were sent to NRC In Word format for eae of review and also for ease of docksting the information. ExeloniAmerGen approval signaturesthese documents may be reviewed on site (e.g., during the Audits) at the Staffs request.

12/5/05 Update (J.G. Hufnagel) rOn Friday. 12/205, electronic copies (in Word format) of the following six AMP PBDs were provided to the NRC Project Manager and NRC AMP/AMR Audit team lead: 8.1.34 (E-1), 8.1.16(Boraflex), 8.1.35 (E-2), 8.1.20 (Fire Water System), B.124 (One Time Inspections) and B.1.29 (Appendix J). These were sixof the nine batch 3 PBDs to be delivered to NRC by 12/S5/0.Today, 12105105, electronic copies (in Word format) of the following approved AMP Basis Documents (PODs) were provided via e-mall to the NRC Project Manager and NRC AMP/AMR Audit teamlead: 8.1.28(ASME Xl, IWF). B.1.16 (Overhead Cranes), and B.1.21 (Above ground tanks). Thie ompleted transmittal do Batch 3of the AMP PDs. wlchwretobetransmitiedbytoday. Theywere sent to NRC In Word format for ease of review and also for ease of dockeiting the information. ExelonlAmerGen approval signatures on these docurnents may be reviewed on site (e.g., duringthe Audits) at the Staifs request.

2t12/12 Update (J.G. Hufnagel)

Thefollowing seven AMP PBDswereprovidedtotheNRC viae-malon December9,2006: PBDB.3.01, Metal Fatigue; PB0 8.1.3i, Eectrical (E-3); P8DB.1.13, OpenCycleCooinggWater, PiD.1.06, 8WR CRD return nozzle; PBD B.1.03. Reactor Head Closure Studs; PBD 0.1,30, Masonry Walls and POD 8.1.05, Feedwater Nozzles. Deliverydo these was confirmed on 12/9 via an e-mailresponse from Greg Cranston, NRC AMP Audit team Lead.

The following two AMP PBDs were completed and transmitted to NRC Project Manager Donnie Ashley and AMP Audit Team Lead Greg Cranston on 12J12t06 PBD 8.1i27, Section Xl IWE and PB08.1.33, Coatings Program. This completes the delivery of Batch 4 of the AMP PBDs, which were to be delivered by 12,1V05.

12/19/05 Update (J.G. Hufnagel)

following three AMP PiDs were provided to the NRC via e-mail on December 168 2005:P808.3.02 EQ, Rev. 0PBDB.1.1OCastAusteniticStainiessSteel.Rev.0PBD B.1.04 Vessel Attachment weids, Rev 0

NRC receipt of these was verbally confirmed with Project Manager Donnie Ashley.

1ie oolbloing four AMP PBDs were comprleted and elecronicaly transmitted to NRC Project Manager Donnie Ashley and AMP Audit Team Lead Gae Cranson o 2It906;BO B.114 CCCW, Rev. 0'BO B.1.32 Water Control Structures, Rev. 0BO B.1.26 Burled Plping, Rev. 0BO B.1.07 BWR SCC, Rev. 0

his cmnpletes delivery, by December 19 2006,5 the upgraded AMP Program Basis Docunents that support the ten element reviews for the agkhg management programs beWng auiited by the

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